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non-resident aliens to the federal territory. We have
never had any income from the federal United States.
Petitioners failed to file a petition for redetermination
with the Court challenging the notice of deficiency.
C. Additional Assessments
On August 26, 1996, respondent assessed the deficiencies and
additions to tax for 1992, 1993, and 1994 determined in the
notice of deficiency dated March 27, 1996, as well as statutory
interest. On August 26, 1996, respondent sent petitioners
notices of balance due, informing petitioners that they had tax
liabilities for 1992, 1993, and 1994 and requesting that they pay
them. Petitioners failed to do so.
D. Petitioners’ Amended Returns
On or about November 9, 1998, petitioners submitted to
respondent Forms 1040X, Amended U.S. Individual Income Tax
Return, for the taxable years 1992, 1993, and 1994. Petitioners
reported that they had no taxable income during the years in
question. Petitioners also asserted that they had erroneously
reported taxable income on their original tax returns.
Petitioners claimed a refund in the amount of $500 for 1992. By
notice dated June 10, 1999, respondent denied petitioners’ refund
claim.
E. Respondent’s Final Notice and Petitioners’ Response
On April 27, 2000, respondent sent petitioners a Notice of
Federal Tax Lien Filing and Your Right to a Hearing Under IRC
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