- 2 - FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. At the time he filed the petition, petitioner resided in Milmay, New Jersey. Petitioner is a habitual nonfiler. In addition to several other years, petitioner did not file income tax returns for 1988 or 1989. In separate notices of deficiency, respondent determined: (1) Deficiencies of $8,174 and $1,616 for 1988 and 1989, respectively; (2) additions to tax pursuant to section 6651(a) of $1,646 and $276.25 for 1988 and 1989, respectively; and an addition to tax pursuant to section 6654(a) of $409.39 for 1988. Petitioner did not receive the notices of deficiency for 1988 and 1989. On May 2, 1994, respondent assessed the aforementioned amounts and interest. On or about May 6, 2002, respondent sent petitioner a Final Notice--Notice of Intent to Levy and Notice of Your Right to a Hearing for 1988 and 1989. On May 30, 2002, petitioner sent respondent a Form 12153, Request for a Collection Due Process Hearing (hearing request). In the hearing request, petitioner claimed he was unemployed during 1988 and 1989, he owed no tax for 1988 and 1989, and that the period of limitations on collection for 1988 and 1989 had expired.Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011