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On April 13, 1995, respondent issued separate notices of
deficiency to petitioner for 1991, 1992, and 1993. In the
notices, respondent determined deficiencies in, and additions to,
petitioner’s Federal income taxes as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654(a)
1991 $198 $100 ---
1992 15,240 3,810 $663
1993 5,781 1,445 239
The deficiencies in income taxes were based on respondent’s
determination that petitioner failed to report nonemployee
compensation, interest income, and unemployment compensation as
reported to respondent by various third-party payors.
Respondent’s records reflect that the notices of deficiency
were not returned undelivered to respondent by the U.S. Postal
Service. Notably, petitioner has not denied that she received
the notices.
C. Assessment of Petitioner’s Liabilities
Petitioner did not file a petition for redetermination with
this Court challenging the notices of deficiency. See sec.
6213(a). Accordingly, on October 24, 1994, respondent assessed
the determined deficiency and additions to tax for 1990, as well
as statutory interest. On that same day, respondent sent
petitioner a notice of balance due, informing petitioner that she
had a liability for 1990 and requesting that she pay it.
Petitioner failed to do so. On November 13, 1995, respondent
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