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in issue. All section references are to the Internal Revenue
Code, as amended.
Background
At the time of filing the petition in the instant case,
petitioner resided in Madison, Connecticut.
Petitioner filed his 1994 and 1995 income tax returns on
October 16 and November 1, 1996, respectively. During 1998 and
1999, respondent, with petitioner’s knowledge, audited
petitioner’s tax returns for the 1994 and 1995 taxable years. On
August 11, 1999, respondent sent petitioner via certified mail a
notice of deficiency addressed to petitioner at his last known
address, 328 County Road, Madison, CT 06443-1640, determining
petitioner owed income tax deficiencies of $15,563.31 and
$6,524.30, additions to tax under section 6651(a)(1) of $3,820.53
and $1,525.33, and penalties under section 6662 of $3,112.66 and
$1,304.86 for taxable years 1994 and 1995, respectively.
Petitioner did not respond to the notice of deficiency by
petitioning the Tax Court within 90 days from August 11, 1999.
On January 3, 2000, respondent assessed the income tax
deficiencies, additions to tax, and penalties for the taxable
years 1994 and 1995 reflected in the notice of deficiency. On
the same day, respondent’s Andover Service Center sent petitioner
a letter requesting that petitioner pay the assessed deficiencies
and additions to tax for the 1994 and 1995 taxable years.
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