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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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