Roger Stoewer - Page 3




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               On December 4, 1998, respondent mailed to petitioner at his            
          Gray Lane address two separate notices of deficiency related to             
          petitioner’s 1996 and 1997 taxable years, respectively.  In one             
          notice of deficiency, respondent determined an income tax                   
          deficiency of $3,775 and an accuracy-related penalty under                  
          section 6662(a) of $465 with respect to petitioner’s 1996 taxable           
          year.  In the other notice of deficiency, respondent determined             
          an income tax deficiency of $4,069 and an accuracy-related                  
          penalty under section 6662(a) of $813.80 with respect to                    
          petitioner’s 1997 taxable year.  Each notice of deficiency stated           
          that the deficiencies could be contested by petitioner’s filing a           
          petition with the Tax Court 90 days from the date of the notices            
          of deficiency.                                                              
               On or about January 12, 1999, petitioner sent two virtually            
          identical letters to respondent, one for each taxable year at               
          issue, which contested the authority of the notices of                      
          deficiency.  Petitioner did not file a petition with the Tax                
          Court with respect to the notices of deficiencies.                          
               On May 24, 1999, respondent assessed the income tax                    
          deficiencies and accuracy-related penalties against petitioner              
          with respect to his 1996 and 1997 taxable years.                            
               On June 14, 1999, respondent assessed a section 6702                   
          frivolous return penalty with respect to each of petitioner’s               
          taxable years at issue.                                                     






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