- 2 -
MEMORANDUM FINDINGS OF FACT AND OPINION
NIMS, Judge: This case arises from a petition for judicial
review filed in response to a “NOTICE OF DETERMINATION CONCERNING
COLLECTION ACTION(S) UNDER SECTION 6320 and/or 6330”. The issue
for decision is whether respondent may proceed with collection
action as so determined. Unless otherwise indicated, section
references are to sections of the Internal Revenue Code, as
amended.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of the parties, with accompanying exhibits, are
incorporated herein by this reference. At the time the petition
was filed in this case, petitioner resided in Rancho Santa
Margarita, California.
Petitioner did not timely file Forms 1040, U.S. Individual
Income Tax Return, for taxable year 1989, 1990, or 1991. On May
19, 1994, respondent by certified mail sent a statutory notice of
deficiency to petitioner for the 1989, 1990, and 1991 years. The
notice was addressed to petitioner at “109 23RD STREET, UNIT 1,
NEWPORT BEACH, CA 92663-4309”, and nothing in respondent’s
administrative files indicates that it was returned as
undeliverable or unclaimed. Respondent in the notice determined
the deficiencies and additions to tax set forth below:
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011