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the addition to tax under section 6651(a)(1) for failure to
timely file a Federal income tax return. Petitioner resided in
Tuscaloosa, Alabama, at the time the petition was filed.
Background
On April 15, 1996, petitioner timely filed an extension of
time to file his 1995 Federal income tax return and remitted a
payment of $4,700. Petitioner, however, did not file his return
on or before the expiration of the extended time. On February 3,
2000, respondent issued a so-called 30-day letter to petitioner.
Petitioner did not directly respond to the 30-day letter.
Instead, petitioner filed his 1995 return on April 6, 2000.
Petitioner reported, inter alia, a tax due of $5,008, an
estimated tax penalty of $75, and the amount paid of $4,700.
Petitioner submitted an additional payment of $383 with his 1995
return.
On May 15, 2000, respondent sent a letter entitled “We
Changed Your Account” (May 2000 letter) to petitioner. The May
2000 letter notified petitioner that respondent had received
petitioner’s return and assessed the tax due reported on the
return. The May 2000 letter stated in pertinent part:
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