Fletcher H. Hyler - Page 2

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          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 a             

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