Lance Standifird - Page 3




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          for failure to file a timely Federal income tax return.                     
          Petitioner did not petition the Court with respect to the notice.           
          On March 4, 1996, respondent assessed petitioner’s tax liability            
          for 1990 as per the notice of deficiency.                                   
               On April 20, 1993, petitioner filed a 1991 U.S. nonresident            
          alien income tax return in which he again reported zero taxable             
          income.  He further reported that he was not a U.S. citizen and             
          that he was “stateless.”  Once again, petitioner stated that his            
          country of residence was “America.”                                         
               On September 3, 1993, respondent issued to petitioner a                
          notice of deficiency for 1991.  The notice determined that                  
          petitioner was liable for a $10,974 deficiency in his 1991 income           
          tax, a $2,744 addition to tax under section 6651(a)(1) for                  
          failure to file a timely Federal income tax return and a $628               
          addition to tax under section 6654 for failure to pay estimated             
          tax.  Petitioner petitioned the Court with respect to the notice.           
          On July 31, 1995, this Court dismissed that case for failure to             
          state a claim upon which relief may be granted.  Standifird v.              
          Commissioner, T.C. Memo. 1995-348.  On January 29, 1996,                    
          respondent assessed petitioner’s tax liability for 1991 as per              
          the notice of deficiency.                                                   
               On February 12, 1999, respondent mailed to petitioner a Form           
          L1058, “Final Notice - Notice of Intent to Levy and Notice of               
          Your Right to a Hearing” (final notice).  The final notice                  






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