-2-
shall sustain respondent’s determination as to the proposed levy.
Section references are to the applicable versions of the Internal
Revenue Code. Rule references are to the Tax Court Rules of
Practice and Procedure.
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulated facts and the exhibits submitted therewith are
incorporated herein by this reference.
Petitioner failed to file Federal income tax returns for
1985 and 1986. The record establishes that respondent filed
substitutes for returns for those taxable years on February 7,
1990.
On September 28, 1994, respondent sent a notice of
deficiency to petitioner.1 The notice determined that petitioner
was liable for a $4,489 deficiency in his 1985 income tax and
additions to tax under sections 6651, 6653(a)(1), and 6654
totaling $1,601. The notice also determined that petitioner was
liable for the time-sensitive addition to tax under section
6653(a)(2).
Petitioner did not petition the Court with respect to the
notice. That notice was returned to respondent with a
handwritten note on the envelope: “moved from this address.”
1 The notice pertained to 1983, 1984, and 1985. Because the
current action involves only 1 of these 3 years, namely, 1985, we
limit our discussion accordingly.
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