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Background
The record establishes and/or the parties do not dispute the
following:
At the time the petition for lien or levy action under
section 6320(c) or 6330(d)1 was filed, petitioner resided in Far
Rockaway, New York.
Respondent’s transcripts for petitioner’s taxable years 1994
and 1996 indicate that he did not file a Federal income tax
return (return) for either of those years and that respondent
prepared a substitute for return for each such year. On a date
not disclosed by the record, respondent mailed to petitioner a
notice of deficiency (notice) with respect to his taxable years
1994 and 1996. The U.S. Postal Service (Postal Service) returned
that notice to respondent because petitioner no longer resided at
the address for petitioner shown on the envelope in which the
notice was mailed and petitioner’s request to the Postal Service
to forward his mail to a new address had expired.
On October 11, 1999, respondent assessed the Federal income
tax (tax) due for each of the petitioner’s taxable years 1994 and
1996, as shown in the substitute for return for each such year
that respondent had prepared, and issued notices and demands for
payment of such taxes.
1All section references are to sections of the Internal
Revenue Code in effect at all relevant times. All Rule refer-
ences are to the Tax Court Rules of Practice and Procedure.
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Last modified: May 25, 2011