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sent to petitioner a notice of deficiency determining a
deficiency in tax of $3,412 for 1989 and additions to tax under
sections 6651(a) and 6654(a); that letter was sent to an address
on Roydon Drive in Houston, Texas. The notice of deficiency was
returned to the IRS marked: “MOVED, LEFT NO ADDRESS”. The
deficiency determination was based on third-party reporting of
wages earned by petitioner in 1989. The notice of deficiency set
forth: “Total income reported by payers (see income sources):
$23,374.00". The amounts included in the notice were reported to
the IRS on Forms W-2, Wage and Tax Statement, that reflected an
address for petitioner on Jeanetta in Houston, Texas.
When petitioner failed to respond to the November 24, 1993,
notice of deficiency, on April 18, 1994, the IRS assessed the
amounts determined in the notice and accrued interest. When the
IRS received petitioner’s 1989 Form 1040, U.S. Individual Income
Tax Return, in 2000, the IRS assessed an additional amount of
$384, the difference between the amount determined in 1993 and
the amount of tax reported on petitioner’s return filed in 2000.
On June 16, 2003, the IRS sent to petitioner a Notice of
Federal Tax Lien Filing and Your Right to a Hearing Under IRC
6320. The notice set forth petitioner’s unpaid liability for
1989 as $6,675.75, which included the two assessments of tax and
accrued additions to tax, penalties, and interest. Petitioner
submitted a Request for a Collection Due Process Hearing. On
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