Brandon Christopher Merriweather - Page 2




                                        - 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.                                              





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