Allan L. Blank - Page 4

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               On May 24, 1995, respondent sent a notice of deficiency for            
          the 1992 taxable year to petitioner at the Florida address,                 
          determining a deficiency of $1,294 and an addition to tax under             
          section 6651(a) of $323.                                                    
               On August 9, 1995, respondent sent a notice of deficiency              
          for the 1993 taxable year to petitioner at the Florida address              
          determining a deficiency of $3,135 and additions to tax under               
          sections 6651(a) and 6654(a) of $783 and $131, respectively.                
               Apparently, petitioner did not receive the aforesaid notices           
          of deficiency.  Respondent conceded this and stated that this was           
          because petitioner had moved to New York in 1991 and the Internal           
          Revenue Service had no notice as to his new address.                        
               On September 25, 1999, respondent sent a letter to                     
          petitioner at his Palo Alto, California, address which provided a           
          summary of the assessed taxes and additions to tax for each of              
          the taxable years at issue.                                                 
               On October 20, 2000, respondent sent petitioner a Letter               
          3172, Notice of Federal Tax Lien Filing And Your Right To A                 
          Hearing.  Petitioner filed a Form 12153, Request for a Collection           
          Due Process Hearing with respondent on November 2, 2000.                    
          Petitioner stated that he had not been contacted by respondent              
          prior to October 1999, that he had responded to all calls and               
          letters since that date, and that he was “never given a chance to           
          appear at an office”.  Petitioner did not dispute the amount of             






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