-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.
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