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FINDINGS OF FACT
None of the facts have been stipulated. At the time he
filed the petition, petitioner resided in Billings, Montana.
Petitioner timely filed Federal income tax returns for 1987,
1988, and 1989. Petitioner did not file a Federal income tax
return for 1992.
On April 25, 1991, petitioner filed a Form 872-A, Special
Consent to Extend the Time to Assess Tax for 1988.
On May 14, 1993, respondent sent notices of deficiency for
1987, 1988, and 1989 to petitioner’s last known address.
On January 14, 1994, respondent filed a Notice of Federal
Tax Lien Under Internal Revenue Laws regarding petitioner’s
assessed income tax liabilities for 1987, 1988, 1989, and 1990
with the County Recorder of Utah County, Provo, Utah.
On December 19, 1997, respondent sent a notice of deficiency
for 1992 to petitioner’s last known address.
On March 6, 2000, respondent filed a Notice of Federal Tax
Lien regarding petitioner’s assessed income tax liability for
1992 with the Clerk and Recorder of Yellowstone County, Billings,
Montana.
On March 15, 2000, respondent sent petitioner a Final
Notice, Notice of Intent to Levy and Notice of Your Right to a
Hearing (collection notice) with respect to petitioner’s 1987,
1988, 1989, and 1992 taxable years. Respondent listed the total
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