- 3 - On June 7, 2001, we issued an opinion in MatrixInfoSys Trust v. Commissioner, T.C. Memo. 2001-133, in which we sustained income tax deficiencies and additions to tax against petitioner as follows: Additions to Tax Year Deficiency Sec. 6651(a)(1) Sec. 6654 1994 $20,340 $5,085 $1,055 1995 20,176 5,044 1,094 1996 19,447 4,862 1,035 1997 18,366 4,592 983 In addition, we imposed a penalty under section 6673(a)(1) of $12,500. All of these amounts shall hereinafter be collectively referred to as the “unpaid liability”. Decision was entered in MatrixInfoSys Trust on July 9, 2001. Petitioner subsequently appealed the decision to the Court of Appeals for the Ninth Circuit. Petitioner did not file a bond with this Court at the time he filed his Notice of Appeal in that case. Respondent assessed the unpaid liability plus interest and mailed Statutory Notices of Balance Due with regard thereto on February 25, 2002. On or about June 6, 2002, respondent sent petitioner a Letter 1058, Final Notice of Intent to Levy and Notice of Your Right to a Hearing, with respect to the unpaid liability. Petitioner timely requested a hearing under section 6330(b). In his request, petitioner asserted that respondent’s collection actions were premature, given that an appeal in MatrixInfoSysPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011