-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.
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