- 3 - Section references are to the Internal Revenue Code as amended. FINDINGS OF FACT Some of the facts have been stipulated and are so found. Petitioner resided in California when he filed the petition in this case. A. Petitioner’s Tax Returns and the Notices of Deficiency Petitioner filed purported Federal income tax returns for 1990-96 in May 1997, and he timely filed a purported 1997 return on April 15, 1998.2 On each return, he reported that he had no wages, other income, or tax liability. After petitioner filed those tax returns and before October 1999 (when respondent issued the notice of intent to levy discussed at paragraph B, below), respondent assessed the frivolous return penalty under section 6702 for 1990-97. Respondent issued notices of deficiency to petitioner for each of his 1990-97 tax years determining deficiencies and additions to tax as follows: 2 Petitioner’s 1997 return bears the date “04-14-97". The parties stipulated that petitioner filed his 1997 return on or before Apr. 15, 1998.Page: 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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