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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.
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Last modified: May 25, 2011