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1996, 1997, and 1998, respectively. Forms 1099-R, Distributions
From Pensions, Annuities, Retirement or Profit-Sharing, IRAs,
Insurance Contracts, etc., issued to petitioner reflect the
taxable portions of those gross distributions as $28,893.99,
$31,426.69, and $32,468.25, respectively.
On or about June 15, 1999, petitioner filed his Federal
income tax returns for the taxable years 1996, 1997, and 1998.2
There is no indication that petitioner received an extension to
file for any of those years. Petitioner reported the
distributions he received from the plan and the resulting tax
liability on his tax returns, but made no tax payments.
Respondent sent petitioner a letter titled “Proposed
Individual Income Tax Assessment” on September 15, 1998. This
letter states that petitioner failed to file a return for the
taxable year 1996 and includes respondent’s calculation of his
income tax liability. Respondent also claims he issued a notice
of deficiency to petitioner for the taxable year 1996 on May 13,
1999.3 Petitioner denies receiving any such notice.
2 Petitioner initially failed to sign all three tax returns
but later ratified them by means of a declaration signed on July
22, 1999.
3 The Sept. 15, 1998, letter and the notice of deficiency
appear to contradict other documents in the record. For example,
respondent assessed $2,299 for the taxable year 1996; however,
the Sept. 15, 1998, letter and the notice of deficiency each
shows a tax liability of $6,654, excluding additions to tax.
Furthermore, while the Sept. 15, 1998, letter shows prepayment
(continued...)
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