Gregory Charles Carlo - Page 2

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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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