-2- respect to petitioner’s unpaid income taxes for 1989, 1990, and 1999.2 The parties dispute whether respondent provided petitioner an opportunity for a hearing as required by section 6330(b) and whether petitioner received a notice of deficiency for 1989, 1990, and 1999. We conclude that respondent did not provide petitioner an opportunity for a hearing and that petitioner did not receive the notice of deficiency. We will remand the case to respondent to provide an opportunity for a hearing as required by section 6330(b). FINDINGS OF FACT Some of the facts have been stipulated and are so found. A. Petitioner Petitioner was incarcerated in the Wyoming Correctional Facility, Attica, New York, when the petition was filed. He lived in the State of New York before and after he was incarcerated. Before he was incarcerated, petitioner was a licensed chiropractor practicing in Yonkers, New York. On August 18, 1994, he pleaded guilty to offering a false instrument for filing in the first degree, insurance fraud in the second degree, grand 2 Petitioner’s tax liability for 1999 is no longer at issue.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011