James G. Gilligan - Page 2

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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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