Thomas R. Hochschild, Sr. - Page 3




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          found petitioner to be in criminal contempt for which he was                
          imprisoned.                                                                 
               Based on petitioner’s allegations that were contained in his           
          appeal of the contempt conviction, he believed that the Assistant           
          U.S. Attorney, Federal District Court, and many others were                 
          involved in a conspiracy against him.  In some manner, petitioner           
          is convinced that the IRS is also conspiring against petitioner.            
               After petitioner failed to file returns, respondent’s agent            
          attempted to elicit returns from petitioner, but none were                  
          forthcoming.  Accordingly, respondent prepared substitute returns           
          based on Forms 1099 and W-2, Wage and Tax Statement, received               
          from Crystal Window Cleaning Co., and Hochschild Management, both           
          of which are petitioner’s companies.  On November 5, 1993,                  
          respondent mailed, via certified mail, a statutory notice of                
          deficiency to petitioner, at his last known address containing              
          the determination that petitioner had income tax deficiencies and           
          additions to tax as follows:                                                
                                   Additions to Tax                                   
               Year    Deficiency   Sec. 6651(a)(1)     Sec. 6654(a)                  
               1989      $15,201        $2,588              $94                       
               1990      12,254         2,001               494                       
               1991      15,223         2,728               600                       
          After two attempts at delivery, the  U.S. Postal Service returned           
          the notice of deficiency, stamped “unclaimed” to respondent.                
               Petitioner did not file a petition, and respondent assessed            
          the deficiencies and began with collection procedures.  Following           





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