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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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