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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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