- 2 - Brian and Tina Nicklaus, pro sese. Kenneth P. Dale, for respondent. OPINION CHIECHI, Judge: The petition in this case was filed in response to a “NOTICE OF DETERMINATION CONCERNING COLLECTION ACTION(S) UNDER SECTION 6320 and/or 6330" (notice of determina- tion). Background The record establishes and/or the parties do not dispute the following: At the time the petition in this case was filed, petition- ers’ mailing address was in Stevenson, Washington. On September 12, 1995, petitioners filed their Federal income tax return (return) for 1993, and on September 19, 1995, petitioners filed their return for 1994. On January 28, 1998, pursuant to section 6020(b)1 respondent prepared substitute returns for petitioners’ taxable years 1995 and 1996, respec- tively. On April 3, 1998, respondent issued a notice of defi- ciency (notice) with respect to each of petitioners’ taxable years 1993 through 1996. Petitioners did not petition the Court in order to dispute respondent’s determinations in those notices. 1All section references are to the Internal Revenue Code in effect at all relevant times.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011