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Federal income taxes of approximately $10,925.41.1 Currently,
the case is before the Court on respondent’s motion for summary
judgment under Rule 121.
We shall grant respondent’s motion for summary judgment.
Unless otherwise noted, section references are to the applicable
versions of the Internal Revenue Code. Rule references are to
the Tax Court Rules of Practice and Procedure.
Background
Petitioner failed to file Federal income tax returns for
1994, 1995, and 1996. On April 23, 1998, respondent prepared
substitutes for returns for petitioner for the respective years.
On September 29, 1999, respondent sent to petitioner a
notice of deficiency for 1994, 1995, and 1996. The notice
determined that petitioner was liable for deficiencies in his
1994, 1995, and 1996 Federal income taxes and additions to tax as
follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1994 $2,239 $314 $59.53
1995 2,269 324 64.42
1996 2,494 575.50 121.39
On November 7, 1999, petitioner sent to respondent a letter
acknowledging receipt of the notice of deficiency. That letter
stated:
1 We use the term “approximately” because these amounts were
computed before the present proceeding and have since increased
on account of interest.
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