- 4 - Respondent prepared a substitute tax return1 for petitioner based on the information reported to respondent by third parties. The substitute tax return reported adjusted gross income of $122,429, which included $853 in wages, $116,188 from the sale of stocks and bonds, $5,129 in dividends, and $259 in interest. On July 5, 2000, respondent issued a statutory notice of deficiency for 1996 to petitioner’s last known address. Respondent determined a deficiency of $31,089, a section 6651(a)(1) failure-to-file penalty of $6,991.42, a section 6651(a)(2) failure-to-pay penalty of $7,768.25, a section 6654(a) estimated tax penalty of $1,653.79. Petitioner received the notice of deficiency but did not petition the Tax Court for redetermination, and respondent assessed a total tax liability of $60,126.33.2 Respondent subsequently issued a Final Notice Notice of Intent to Levy and Notice of Your Right to a Hearing. In the notice, respondent informed petitioner of respondent’s intent to levy and of petitioner’s right to a hearing before respondent’s Appeals Office pursuant to section 6330. In response, petitioner 1We are not called on to decide whether the return prepared by respondent met the requirements of a substitute return under sec. 6020(b). See Swanson v. Commissioner, 121 T.C. 111, 112 n.1 (2003). 2The assessed tax liability included a deficiency of $31,089, a sec. 6651(a)(1) penalty of $6,991.42, a sec. 6651(a)(2) penalty of $6,836.06, a sec. 6654(a) penalty of $1,653.79, and $13,572.06 of interest.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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