James L. Jensen - Page 4

                                        - 4 -                                         
               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:                                    






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next

Last modified: May 25, 2011