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Background
Petitioner did not file a 1999 Federal income tax return.
Consequently, on March 12, 2004, respondent mailed a notice of
deficiency for 1999 to petitioner’s last known address. In the
notice of deficiency, respondent determined a deficiency in
petitioner’s 1999 Federal income tax of $46,434, a section
6651(a)(1) failure-to-file addition to tax of $10,354.50, a
section 6651(a)(2) failure to pay addition to tax,1 and a section
6654 estimated tax addition to tax of $2,229.95.
Petitioner timely petitioned this Court for a
redetermination of the deficiency. At the time of filing the
petition, petitioner resided in North Chatham, Massachusetts.
The petition made the following contentions:
I would like to have a redetermination because the
forms I was sent have me as single with no dependents,
I am married with 2 children. In 1999 I sent all my
deductions & tax information to my accountant. I am
willing to pay my share, but the amount listed is more
than I make in a year. Enclosed is a payment towards
my 1999 taxes, so I can begin to pay something.
The Court’s notice setting case for trial and standing
pretrial order were served on October 1, 2004, and this case was
calendared for trial on March 7, 2005. In pertinent part, the
notice states:
The calendar for that Session will be called at
10:00 A.M. on that date and both parties are expected
1The amount of any addition to tax under sec. 6651(a)(2)
shall be determined pursuant to sec. 6651(a)(2), (b), and (c).
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Last modified: May 25, 2011