- 2 -
as determined in the notice of determination with respect to
petitioner’s taxable years 1994, 1995, and 1996. We hold that
respondent did abuse respondent’s discretion with respect to
petitioner’s taxable year 1994 and that respondent did not abuse
respondent’s discretion with respect to petitioner’s taxable
years 1995 and 1996.
FINDINGS OF FACT
Most of the facts have been stipulated by the parties and
are so found except as noted below.
Petitioner resided in Chicago, Illinois, at the time he
filed the petition in this case.
On March 29, 1999, respondent prepared a substitute for
return with respect to each of petitioner’s taxable years 1994,
1995, and 1996.
On or about April 5, 1999, respondent mailed to petitioner a
so-called 30-day letter, Letter 2566 (30-day letter), for each of
his taxable years 1994, 1995, and 1996. In those respective 30-
day letters, respondent advised petitioner that respondent had no
record of having received Federal income tax (tax) returns for
those years and proposed assessments for those years based upon
information returns that respondent had received from third-party
payers. In the respective 30-day letters pertaining to peti-
tioner’s taxable years 1994, 1995, and 1996, respondent also
requested petitioner to file a tax return for each of those
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011