3
Background
The parties have stipulated or otherwise do not dispute the
following.
At the time of filing the petition in the instant case,
petitioner resided in Grimstead, Virginia. Petitioner is a
college graduate.
On November 15, 1996, respondent sent petitioner a notice of
deficiency, determining Federal income tax deficiencies for the
taxable years 1991, 1992, 1993, and 1994. Petitioner received
the notice of deficiency.
On February 7, 1997, petitioner timely filed a petition with
this Court for a redetermination of the deficiency.
On October 9, 1998, this Court issued an opinion in
petitioner's case, see Forrest v. Commissioner, T.C. Memo. 1998-
369, followed by entry of decision on October 30, 1998,
sustaining the 1991-94 deficiencies in full and imposing a $500
penalty under section 6673(a)(1) upon petitioner for making
frivolous arguments.
Respondent issued a Notice of Balance Due for each of the
years 1991 through 1994 on April 26, 1999.
On May 27, 2002, respondent sent petitioner a Letter 1058,
Final Notice--Intent to Levy and Notice of Your Right to a
Hearing, advising petitioner that respondent intended to levy and
collect unpaid income tax liabilities for 1991, 1992, 1993, and
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