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1988 Federal income tax and related liabilities of $17,801.2 In
response to that notice, petitioner timely petitioned this Court
for review of respondent’s determination to proceed with
collection. Our jurisdiction in this case is established by
section 6330(d).
Background
Some of the facts in this case have been stipulated and are
so found. At the time the petition was filed, petitioner was a
resident of California.
Petitioner’s untimely 1988 Federal income tax return was
filed on January 13, 1991. On the return, petitioner’s address
is shown as 24143 Palomino Dr., Diamond Bar, California (the
Diamond Bar address). Petitioner reported wages of $42,926 from
his employment as an engineer with General Dynamics Corp. There
were no Federal income tax withholdings on petitioner’s wages
from General Dynamics Corp. There are two Schedules C, Profit or
Loss From Business, included with petitioner’s return. One is
for a business described as a “tax preparation/consulting”
service; the other is for a business described as a “property
management” service. Approximately $5,100 of gross income is
reported and approximately $21,000 of expenses are deducted on
2 Other liabilities were referenced in the notice, but this
Court has no jurisdiction over respondent’s determination with
respect to those liabilities. See the Jan. 10, 2000, Order
granting respondent’s Motion to Dismiss for Lack of Jurisdiction
and to Strike as to the 1990 Tax Return Preparer Penalty.
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