Michael Stein - Page 2

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          petitioner statutory notices of deficiency to which he never                
          responded, and thereafter assessed income tax liabilities against           
          petitioner for those years.                                                 
               As of March 8, 1999, petitioner’s total unpaid tax                     
          liabilities for the above-mentioned years, including the unpaid             
          assessed income tax liabilities, and additions to tax and                   
          interest, were as follows:                                                  
                    Unpaid        Additions to Tax     Total Unpaid                   
               Year    Assessments     and/or Interest      Liabilities               
               1992     $1,344.17         $1,068.95    $2,413.12                      
          1993      5,505.15          1,910.12         7,415.27                       
          1994    197,079.49         63,903.26         260,982.75                     
               On February 23, 2000, respondent filed a notice of Federal             
          tax lien (NFTL) against petitioner’s real property with respect             
          to $203,928.81, the then-unpaid balance of petitioner’s 1992                
          through 1994 tax liabilities.  On July 26, 2001, respondent                 
          issued petitioner a notice of determination concerning collection           






               1(...continued)                                                        
          Commissioner where the taxpayer did not file a return.  See                 
          Swanson v. Commissioner, 121 T.C. 111, 112 n.1 (2003).  The term            
          “SFR” has also been used to describe a return prepared by the               
          Commissioner under sec. 6020(b).  There is no record evidence to            
          prove or disprove respondent’s assertion in his brief that the              
          substitutes for return in this case meet the requirements of sec.           
          6020(b).  For convenience, we refer to the returns prepared by              
          respondent as SFRs.                                                         






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