- 2 - This case is before the Court on respondent's motion for summary judgment under Rule 121. This proceeding arises from a petition for judicial review filed in response to a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 sent to petitioner. Background Respondent issued to petitioner a notice of deficiency for taxable years 1994 and 1995. The notice determined deficiencies of $12,510 and $10,626 for 1994 and 1995, respectively. The notice also determined an addition to tax under section 6651(a)(1) for failure to timely file an income tax return for 1994 of $2,720. In addition, respondent issued to petitioner a notice of deficiency for taxable year 1996 determining a deficiency of $3,878 and an accuracy-related penalty under section 6662(a) of $776. Both notices were sent to petitioner and his wife, Lan Thi Nguyen,1 at 316 Pennsylvania Avenue, Downingtown, Pennsylvania 19335-2645. Neither petitioner nor his wife filed a petition with the Tax Court in response to the notices of deficiency. Subsequently, respondent assessed the deficiencies and interest for tax years 1994 and 1995. Respondent also assessed the 1Mrs. Nguyen did not sign the Form 12153, Request for a Collection Due Process Hearing, or participate in the collection due process hearing and is not a party to this case.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011