- 2 - Background On October 29, 1998, respondent issued a notice of deficiency to petitioner determining a deficiency of $2,891 in his Federal income tax for 1997. The notice of deficiency may not have been mailed to petitioner at his last known address. In any event, the notice of deficiency was returned to respondent by the Postal Service and was not received by petitioner. On November 18, 1998, respondent issued a notice of deficiency to petitioner determining deficiencies of $2,126 and $2,623 in his Federal income taxes for 1995 and 1996, respectively. This notice of deficiency was mailed to petitioner at his last known address. Petitioner does not assert that he did not receive the notice of deficiency.2 However, petitioner failed to file a petition with the Court challenging the notice of deficiency pursuant to section 6213(a). On October 14, 1999, respondent mailed to petitioner a Final Notice/Notice Of Intent To Levy And Notice Of Your Right To A Hearing (notice of intent to levy) pursuant to section 6331(a). The notice stated that petitioner owed taxes and statutory additions totaling $1,453.37, $3,267.96, and $3,307.40 for the 1(...continued) Practice and Procedure and, unless otherwise indicated, all section references are to the Internal Revenue Code, as amended. 2 Indeed, petitioner attached a partial copy of this notice of deficiency to his petition.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011