- 2 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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