- 2 -
proceed with collection with respect to petitioner’s tax years
1990-91 was an abuse of discretion. We hold that it was not.
Section references are to the Internal Revenue Code as
amended.
FINDINGS OF FACT
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 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 67021 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:
1 We will dismiss for lack of jurisdiction the portion of
this case that relates to the frivolous return penalties for tax
years 1990-91. Van Es v. Commissioner, 115 T.C. 324, 328-329
(2000).
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