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