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(2) decided that there were due from petitioner for his taxable
years 1993 and 1994 deficiencies in his Federal income tax (tax)
in the respective amounts of $108,542 and $121,983 and additions
to such tax in the respective amounts of $21,708 and $24,397.
On April 13, 1999, the Court granted petitioner until June
11, 1999, within which to file a motion to vacate the April 12,
1999 Order of Dismissal and Decision in the case at docket No.
2446-98. That was because petitioner had telephoned the Clerk of
the Court and indicated that he had not received until April 11,
1999, the Order setting the case at docket No. 2446-98 for trial
on April 12, 1999, in Washington, D.C.
On June 8, 1999, petitioner filed a motion to vacate the
April 12, 1999 Order of Dismissal and Decision. On July 9, 1999,
the Court denied that motion to vacate.
On September 29, 1998, respondent mailed to petitioner a
notice of deficiency (September 29, 1998 notice) with respect to
his taxable year 1995, which he received. In the September 29,
1998 notice, respondent determined a deficiency in, and an
addition to, petitioner’s tax for his taxable year 1995 in the
respective amounts of $432,990 and $21,581. Petitioner did not
file a petition in the Court with respect to the September 29,
1998 notice relating to his taxable year 1995.
On September 22, 2000, respondent filed a notice of Federal
tax lien with the Recorder of Deeds in Washington, D.C., with
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