Brian and Tina Nicklaus - Page 2




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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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