- 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