Michael J. Roberts - Page 4




                                        - 4 -                                          
          respondent from third-party payors and used in calculating the               
          determined deficiencies.  The Schedules C also contained                     
          deductions claimed by petitioner for various business                        
          expenditures, such as for car and truck expenses, travel, meals              
          and entertainment, and small tools.                                          
               Petitioner did not file a petition with this Court for a                
          redetermination of the tax liabilities asserted in the statutory             
          notice.  The record in this case does, however, include a copy of            
          a letter dated September 29, 1994, contained in respondent’s                 
          administrative files and addressed to petitioner at the Newport              
          Beach location.  This letter indicates that it was sent in                   
          response to petitioner’s inquiry regarding the notice of                     
          deficiency dated May 19, 1994, and informs petitioner that the               
          date for filing a petition with the Tax Court had expired.                   
          Respondent made assessments based on the amounts shown in the                
          notice, plus statutory interest, on December 5, 1994, and issued             
          to petitioner a notice of balance due on the same date (as well              
          as on three subsequent occasions).                                           
               On May 26, 1999, respondent issued to petitioner a letter               
          entitled “FINAL NOTICE--NOTICE OF INTENT TO LEVY AND NOTICE OF               
          YOUR RIGHT TO A HEARING” with respect to the unpaid tax                      
          liabilities for 1989, 1990, and 1991.  Thereafter, on June 25,               
          1999, respondent received a Form 12153, Request for a Collection             
          Due Process Hearing, submitted on behalf of petitioner.                      






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next

Last modified: May 25, 2011