- 10 - BRIEF BACKGROUND The taxpayer filed voluntary income tax returns for 1991, 1994, 1996. The Collection Statute has since expired on the 1991 tax liability. The taxpayer filed frivolous returns for 1997, 1998 and 1999. Frivolous return penalties were assessed for each of these three years. The taxpayer has filed no income tax returns since 1999 even though income information reported to the Internal Revenue Service indicates that he would have a filing requirement. * * * * * * * I. Verification of Legal and Procedural Requirements The required notice and demand was sent for each period on the same date as the assessment. * * * * * * * With the best information available including computer records and the administrative file it has been deter- mined that all applicable legal and administrative requirements have been met. This settlement officer has had no known previous dealings with this taxpayer for the tax liability for the periods listed above. II. Issues Raised by the Taxpayer The taxpayer had an earlier opportunity to raise issues concerning the underlying tax liability for the 1998 and 1999 tax liability. A Statutory Notice of Defi- ciency (SND) was issued for these assessments. It is known that the taxpayer received a copy of this notice because he provided a copy of it with his appeal re- quest. The tax liability on earlier periods [including 1994 and 1996] is based upon voluntarily filed tax returns. The taxpayer was given an opportunity to raise the issue of the underlying tax liability with regards to the Frivolous Income Tax Return Civil Penalty under IRC � 6702 for the tax periods listed above. The taxpayer did not present any relevant, non-frivolous documenta- tion to challenge the liability.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011