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On April 24, 1998, respondent mailed to petitioner notices
of deficiency for 1991 and 1992. The deficiencies were
attributable to respondent’s determination that petitioner owed
self-employment tax on the income reported on his returns. As to
1991, the notice determined that petitioner was liable for a
$5,840 deficiency in income tax and a $1,460 addition to tax
under section 6651(a)(1). As to 1992, the notice determined that
petitioner was liable for a $2,609 deficiency in income tax and a
$652.25 addition to tax under section 6651(a)(1). Petitioner
received both notices of deficiency, but he did not petition the
Court in response to either notice.
On February 18, 1999, respondent issued to petitioner a
Notice of Intent to Levy and Notice of Your Right to a Hearing
for taxable years 1991 and 1992. On or about March 8, 1999,
petitioner requested such a hearing, and the hearing was held on
September 25, 2000. During the hearing, the Appeals officer
concluded that petitioner had “reasonable cause” for failing to
file timely his 1991 and 1992 returns and agreed to abate the
related additions to tax under section 6651(a)(1). Petitioner
also argued during the hearing that his liability for 1991 and
1992 should be offset by the refund claimed on his 1990 return.
The Appeals officer refused to consider this argument.
On February 2, 2001, respondent issued a notice of
determination to petitioner for 1991 and 1992, which abated the
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Last modified: May 25, 2011