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Background
Petitioner failed to file Federal income tax returns for
1994, 1995, and 1996.
On November 30, 1999, respondent sent petitioner a statutory
notice of deficiency for 1994, 1995, and 1996. Petitioner
received the notice of deficiency. Respondent determined
deficiencies in and additions to petitioner’s Federal income tax
as follows:
Additions to Tax
Year Deficiency Sec. 6651(f) Sec. 6654(a)
1994 $6,105 $1,561 --
1995 13,675 9,912 $714
1996 14,324 10,743 762
On April 24, 2000, respondent assessed the tax, additions to
tax, and interest for 1994, 1995, and 1996.
On February 14, 2003, respondent sent petitioner a Final
Notice, Notice of Intent to Levy and Notice of Your Right to a
Hearing with respect to petitioner’s 1994 and 1996 taxable years.
On March 5, 2003, respondent sent petitioner a Final Notice,
Notice of Intent to Levy and Notice of Your Right to a Hearing
with respect to petitioner’s 1995 taxable year.
On or about March 7, 2003, respondent filed a notice of
Federal tax lien regarding petitioner’s 1994, 1995, and 1996 tax
years.
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Last modified: May 25, 2011