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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.
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