-3- 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 noticePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011