-2- against petitioner without offering petitioner a face-to-face hearing. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the year in issue, and all Rule references are to the Tax Court Rules of Practice and Procedure. Background At the time the petition was filed, petitioner resided in Casper, Wyoming. For 2000 through 2003, petitioner did not file Federal income tax returns and apparently did not pay Federal income taxes. Based on third-party information returns, respondent prepared substitute returns for petitioner for the above years. In 2002, respondent mailed to petitioner a notice of deficiency relating to petitioner’s 2000 Federal income tax liability in the approximate amount of $26,000.1 Petitioner did not file a petition in this Court with regard to respondent’s notice of deficiency for 2000. On September 29, 2003, respondent assessed against petitioner the above $26,000 Federal income tax deficiency for 2000, and respondent mailed to petitioner a first notice and demand for payment thereof, plus penalties and interest. 1Respondent apparently has not determined tax deficiencies relating to petitioner’s 2001, 2002, or 2003 Federal income taxes.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011