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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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