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Respondent determined deficiencies and additions to tax in
petitioner's Federal income taxes as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1988 $1,523 $381 $96
1989 1,790 448 121
1990 3,837 959 252
1991 3,869 967 222
1992 2,614 654 114
1993 2,363 591 96
At the time the petition was filed with this Court,
petitioner resided in Ottumwa, Iowa. Petitioner filed an
objection to respondent's motion to dismiss. Respondent filed a
response to petitioner's objection.
Petitioner did not file tax returns for the taxable years
1988 through 1993. The last year for which he filed a return
prior to 1988 was 1986.
On April 4, 1996, respondent mailed petitioner a notice of
deficiency for the years 1988 through 1993. The notice was sent
by certified mail to petitioner at 713 7th St., SW, Albuquerque,
NM 87102-3813 (Albuquerque address). Respondent also sent a
duplicate notice of deficiency on the same day by certified mail
to petitioner at 73 Forest St., Attleboro, MA 02703 (Attleboro
address). The notice of deficiency sent to the Albuquerque
address was returned by the U.S. Postal Service with a notation
of "Unclaimed". The notice of deficiency sent to the Attleboro
address was returned by the U.S. Postal Service with a notation
of "NOT DELIVERABLE AS ADDRESSED – UNABLE TO FORWARD".
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