- 2 - 6330 of the Internal Revenue Code (Decision Letter).1 The issue for decision is whether the Court lacks jurisdiction under sections 6320 and 6330 with regard to the years in issue. FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. At the time he filed the petition, petitioner resided in Loma Linda, California. I. 1995 On April 15, 1999, respondent sent petitioner a notice of deficiency addressed to petitioner at his last known address, 11767 Knightsbridge Place, Loma Linda, CA 92354, determining petitioner owed an income tax deficiency of $185,480 and a penalty under section 6662(a) in the amount of $37,096 for the 1995 tax year. Petitioner did not respond to the notice of deficiency by petitioning the Tax Court within 90 days from April 15, 1999. On August 30, 1999, respondent assessed the additional 1995 tax liability, along with penalties and interest, and mailed notice and demand to petitioner at his last known address. On March 1, 2000, respondent issued to petitioner a Notice of Federal Tax Lien Filing and Your Right to a Hearing Under IRC 1 Unless otherwise indicated, all section references are to the Internal Revenue Code as amended.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011