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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.
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Last modified: May 25, 2011