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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.
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Last modified: May 25, 2011