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By letter dated September 10, 1994, and showing the Madeira
Drive address, petitioner requested additional time to respond to
this request. On April 4, 1995, respondent received from
petitioner a purported Schedule C, Profit or Loss From Business,
listing his principal business as “Property Inspector”, showing
$8,416 of previously unreported income from “Gross receipts or
sales”, and claiming $2,672.72 of previously unclaimed business
expenses, including alleged expenses for travel, film, pager, and
“walking shoes”.
Notice of Deficiency
By notice of deficiency dated May 17, 1995, and mailed to
the Madeira Drive address, respondent adjusted petitioner’s
income to include $10,744 of nonemployee compensation and
determined a $2,782 deficiency in petitioner’s 1992 Federal
income tax and a $556 accuracy-related penalty pursuant to
section 6662. In the notice of deficiency, respondent allowed
petitioner no business expense deduction. The notice of
deficiency contained instructions for filing a petition with the
Tax Court, and indicated that any Tax Court petition should be
filed within 90 days (i.e., by August 15, 1995).
On June 15, 1995, respondent received from petitioner
correspondence, stating: “Here are the copies of milege [sic], &
film & pager & auto care for 92 tax return.” Included in this
correspondence, along with handwritten mileage logs and
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