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When sending the notice of deficiency to petitioner, respondent
used the address petitioner indicated in a stipulated decision of
the Tax Court with respect to petitioner’s 1986 Federal income
tax liability, signed by petitioner on January 24, 1994, and
entered by the Court on January 28, 1994.2 Smith v.
Commissioner, docket No. 13936-93. Petitioner has never filed a
Federal income tax return for 1993, 1994, or 1995. Nor does the
record indicate that petitioner has filed a Federal income tax
return for any of the years from 1983 to 1996. Cf. Smith v.
Commissioner, T.C. Memo. 2000-43 (1992 through 1996 taxable
years), affd. without published opinion 252 F.3d 1357 (5th Cir.
2001).
On February 24, 1999, respondent mailed to petitioner a
Letter 3164 with respect to 1985 and 1986, informing petitioner
of the balance of taxes due, including statutory additions. On
the same date, respondent sent to petitioner a Letter 1058, Final
Notice--Notice of Intent to Levy and Notice of Your Right to a
Hearing as to 1985 and 1986.
On March 1, 1999, petitioner sent to respondent a Form 12153
requesting a collection due process hearing under section 6330.
On November 26, 1999, the Appeals officer mailed to petitioner a
letter suggesting that a hearing be held on January 6, 2000.
2 This address was the address used by the Court throughout
that proceeding.
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Last modified: May 25, 2011