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6320 with respect to the 1995 tax year. Petitioner did not
timely request a hearing in response to the March 1, 2000,
notice.
II. 1996 and 1997
On July 13, 2000, 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 for 1996 of $172,587, a
penalty under section 6662(a) for 1996 in the amount of
$34,517.40, an income tax deficiency for 1997 of $219,010, an
addition to tax under section 6651(a) for failure to file a
return for 1997 within the time prescribed by law in the amount
of $10,942.05, and a penalty under section 6662(a) for 1997 in
the amount of $43,802.
Petitioner did not respond to the notice of deficiency by
petitioning the Tax Court within 90 days from July 13, 2000. On
December 18, 2000, respondent assessed the additional 1996 and
1997 tax liabilities, along with penalties and interest, and
mailed notice and demand regarding the unpaid 1996 and 1997 tax
liabilities to petitioner at his last known address.
On March 19, 2001, respondent issued to petitioner a Notice
of Federal Tax Lien Filing and Your Right to a Hearing Under IRC
6320 with respect to the 1996 and 1997 tax years. Petitioner did
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