- 8 -
Transactions, and Forms 1099-Div, Dividends and Distributions,
from financial institutions that paid investment income to him.
On December 12, 1996, after having prepared SFRs for
petitioner’s tax years at issue, respondent mailed three notices
of deficiency to petitioner determining income tax deficiencies
of $15,812, $10,210, and $153,787 for petitioner’s 1992, 1993,
and 1994 tax years, respectively, failure to file additions to
tax under section 6651(a)(1) of $211 for 1992 and $24,758 for
1994, and additions to tax under section 6654 of $689 for 1992
and $7,352 for 1994 for failure to pay estimated tax.5
Respondent sent the notices of deficiency by certified mail to
the Elm Street address.
On January 8, 1997, the U.S. Postal Service returned to
respondent the notices of deficiency and the covering envelopes
stamped “unclaimed”. The envelopes displayed no indication that
petitioner was no longer using the Elm Street address or that
this address was invalid.
Petitioner did not file petitions with the Court disputing
the determinations set forth in the statutory notices.
On May 5, 1997, respondent assessed income tax liabilities
against petitioner for the tax years at issue on the basis of the
5Respondent did not determine penalties for petitioner’s
1993 tax year.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011