John Thurman and Elaine Sheryl Horejs - Page 5




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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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