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FINDINGS OF FACT2
Petitioners resided in Garden Grove, California, when the
petition in this case was filed.
Separate Liabilities
Petitioner filed his 1990 Federal income tax return late on
September 6, 1991. On July 21, 1993, respondent mailed a
statutory notice of deficiency to petitioner for his 1990 taxable
year. Petitioner did not petition this Court to dispute the
deficiency. On December 20, 1993, respondent assessed the $399
income tax deficiency and a $98.74 late-filing penalty under
section 6651(a)(1). In addition, $104.40 of interest was
assessed. Petitioner does not contest the 1990 tax liability.
Petitioner timely filed his 1991 Federal income tax return
that contained several mathematical errors. Respondent corrected
the mathematical errors in accord with section 6213(b)(1), and
assessments were made to correct the errors. Respondent
subsequently selected petitioner’s 1991 return for an audit
examination. On April 5, 1994, respondent mailed petitioner a
statutory notice of deficiency for his 1991 taxable year
determining a $545 income tax deficiency. Petitioner did not
petition this Court with respect to the 1991 notice of
2 The parties’ stipulation of facts is incorporated by this
reference.
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