- 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