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On August 10, 1999, respondent sent petitioner a statutory
notice of deficiency for 1995. Respondent determined a $97,021
deficiency, a $4,851 penalty pursuant to section 6651(a)(1), and
a $19,404 penalty pursuant to section 6662(a) for 1995.
Petitioner received this notice of deficiency and responded to it
with a 15-page letter containing frivolous and groundless
arguments.
On December 2, 1999, respondent sent petitioner a letter
advising him that his tax returns for 1996 and 1997 were under
examination. On December 12, 1999, petitioner responded with a
two-page letter containing frivolous and groundless arguments.
On April 4, 2000, respondent sent petitioner a statutory
notice of deficiency for 1996 and 1997. Respondent determined an
$8,338 deficiency and a $1,667.60 penalty pursuant to section
6662(a) for 1996 and a $9,317 deficiency and a $1,863.40 penalty
pursuant to section 6662(a) for 1997. This notice of deficiency
was sent via certified mail to petitioner’s last known address--
which also is the address petitioner used in the petition and the
amended petition. This notice of deficiency was not returned as
undeliverable.
Petitioner did not petition the Court for redetermination of
the deficiencies or penalties with respect to 1994, 1995, 1996,
or 1997. Respondent assessed petitioner’s tax liability, along
with penalties and interest, as follows:
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Last modified: May 25, 2011