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Background
The record establishes and/or the parties do not dispute the
following.
At the time he filed the petition in this case, petitioner’s
mailing address was in Lancaster, Ohio.
On or about November 7, 1997, petitioner filed a Federal
income tax (tax) return for his taxable year 1994 (1994 return).
In his 1994 return, petitioner reported, inter alia, taxable
income of $3,823 and tax of $574. Petitioner did not remit any
payment with that return.
On December 29, 1997, respondent assessed petitioner’s tax
as reported in his return, as well as additions to tax under
section 6651(a)(1)3 and (2), and interest as provided by law for
his taxable year 1994. (We shall refer to any such unpaid
assessed amounts, as well as interest as provided by law accrued
after December 29, 1997, as petitioner’s unpaid liability for
1994.)
2(...continued)
lection with respect to petitioner’s tax year 1991 should not
proceed” because the period of limitations for collection with
respect to that year has expired. Respondent further states in
respondent’s motion that “petitioner’s account was cleared to
zero balance upon expiration of the collection statute of limita-
tions”. In light of respondent’s concession with respect to
petitioner’s taxable year 1991, we shall address only peti-
tioner’s taxable years 1994, 1996, 1998, and 1999.
3All section references are to the Internal Revenue Code in
effect at all relevant times. All Rule references are to the Tax
Court Rules of Practice and Procedure.
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