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Petitioner resided in Chicago, Illinois, at the time he
filed the petition in this case.
On July 14, 1993, respondent issued to petitioner a notice
of deficiency (July 14, 1993 notice) with respect to his taxable
years 1987, 1988, and 1989, which he received. In that notice,
respondent determined a deficiency in, and additions under
sections 6651(a)(1) and 66541 to, petitioner’s Federal income tax
(tax) for each of his taxable years 1987, 1988, and 1989.
Petitioner did not file a petition in the Court with respect
to the July 14, 1993 notice relating to his taxable years 1987,
1988, and 1989.
On February 7, 1994, respondent assessed petitioner’s tax,
as well as additions to tax and interest as provided by law, for
his taxable year 1987. (We shall refer to those assessed
amounts, as well as interest as provided by law accrued after
February 7, 1994, as petitioner’s unpaid liability for 1987.)
On February 7, 1994, respondent issued to petitioner a
notice of balance due with respect to petitioner’s unpaid liabil-
ity for 1987. On March 14, 1994, respondent issued a second
notice of balance due with respect to such unpaid liability.
On February 21, 1994, respondent assessed petitioner’s tax,
as well as any penalties and interest as provided by law, for
1All section references are to the Internal Revenue Code in
effect at all relevant times. All Rule references are to the Tax
Court Rules of Practice and Procedure.
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