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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 MatrixInfoSys
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Last modified: May 25, 2011