Lloyd Pragasam - Page 2

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          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.                                       




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