Louis P. Mitchell - Page 2

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          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.                                                                      




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