Joe Shelby Griffith - Page 2

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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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