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Background
Petitioner was born in Alameda, California. At the time he
filed the petition, petitioner maintained a post office box in
Campbell, California. Petitioner claims he was homeless during
this time and lived with friends in California, Nevada, and
Oregon.
For 1992, petitioner initially filed a Form 1040, U.S.
Individual Income Tax Return, and reported a tax liability of
$4,412.2 Petitioner did not remit payment with his return. On
December 6, 1993, the Internal Revenue Service (IRS) assessed
this amount. The IRS sent notice and demand for payment letters
to petitioner on May 2, 1994, and December 2, 1996. On or about
August 20, 1997, petitioner submitted a Form 1040NR, U.S.
Nonresident Alien Income Tax Return, for 1992 and reported a tax
liability of “N/A”.
For 1993, petitioner initially filed a Form 1040 and
reported a tax liability of $2,254. Petitioner did not remit
payment with his return. On November 28, 1994, the IRS assessed
this amount. The IRS sent notice and demand for payment letters
to petitioner on November 28, 1994, and December 2, 1996. On or
about August 20, 1997, petitioner submitted a Form 1040NR for
1993 and reported a tax liability of “N/A”.
On or about August 20, 1997, petitioner filed a Form 1040NR
2 All amounts are rounded to the nearest dollar.
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Last modified: May 25, 2011