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By letter dated September 16, 1998, respondent advised
petitioner that changes had been made to his 1996 return as
described in a report of income tax examination changes enclosed
with the letter.
On April 15, 1999, respondent mailed, by certified mail, a
notice of deficiency with respect to petitioner’s 1995 and 1996
taxable years to petitioner’s last known address at 768 Florecita
Lane, Altadena, CA 91001. Petitioner did not file a petition in
this Court to contest the notice of deficiency. On August 9,
1999, respondent assessed the income tax deficiencies, additions
to tax, and penalties set forth in the notice of deficiency, and
statutory interest.
On a date that does not appear in the record, petitioner
again asked respondent to reconsider petitioner’s 1995 and 1996
tax liabilities. By letter dated June 21, 2000, respondent
advised petitioner that he would need to provide respondent with
documentation before respondent could grant an audit
reconsideration for 1995 and 1996. Respondent requested that
petitioner provide the documentation by July 13, 2000.
Petitioner did not provide the requested documentation, so
petitioner’s request was denied. By letter dated December 27,
2000, respondent explained to petitioner why a conference had not
been granted as requested by petitioner.
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