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On August 16, 1999, respondent sent petitioner a notice of
deficiency for 1995 and 1996. In it, respondent determined that
petitioner had self-employment income of $161,864 for 1995 and
$132,795 for 1996, interest income of $63 for 1995 and $219 for
1996, and pensions and annuities of $124 for 1996. Respondent
allowed on Schedule C, Profit or Loss From Business, expenses of
$81,579 for 1995 and $66,929 for 1996 on the basis of the
Schedule C expenses that petitioner had reported on his 1994
return. Respondent determined deficiencies and additions to tax
as follows:
Additions to Tax
Year Deficiency Sec. 6651(a)(1) Sec. 6654
1995 $27,405 $6,851.25 $1,485.99
1996 22,506 5,626.50 1,197.91
The notice of deficiency was returned to respondent as
undeliverable to petitioner. Respondent assessed tax and
interest for 1995-96 on December 27, 1999, and sent petitioner
notices of balance due for those years on December 27, 1999,
January 31, 2000, and March 6, 2000. Petitioner filed his 1998
return on April 20, 2000, and his 1997 return on December 6,
2000.
On September 28, 2000, respondent sent petitioner a Notice
of Federal Tax Lien Filing and Your Right to a Hearing Under
I.R.C. � 6320 relating to taxes respondent had assessed for 1995-
96 (the September 2000 lien notice). On October 2, 2000,
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