- 2 - the Notice of Federal Tax Lien. After concessions, the issues for decision are: (1) Whether notices of deficiency regarding petitioner’s tax liabilities for 1995 and 1997 were barred by a directive from the National Taxpayer Advocate’s office; (2) whether notices of deficiency for 1995 and 1997 were sent to petitioner’s last known address; (3) whether petitioner was denied due process with respect to the notice of lien; and (4) whether assessment of taxes and penalties for 1995 was barred by the statute of limitations or otherwise violated applicable regulations. Unless otherwise indicated, all section references are to the Internal Revenue Code, as amended. FINDINGS OF FACT Some of the facts have been stipulated, and the stipulated facts are incorporated in our findings by this reference. Petitioner resided in Portola Valley, California, at the time he filed his petition. Petitioner holds at least one advanced academic degree and has lectured at the Stanford School of Business. During the years in issue, petitioner and his spouse owned a marketing corporation, Logical Marketing, Inc. Petitioner served as its chief executive officer. On or about March 9, 1998, petitioner agreed to a decision in this Court at docket No. 25288-96 determining a deficiency in income tax due from him for 1993 in the amount of $57,255 and aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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