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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.
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Last modified: May 25, 2011