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and petitioner’s motion for partial summary judgment.1
Petitioners filed a petition in response to respondent’s Decision
Letters Concerning Equivalent Hearing under Section 6320 and/or
6330 of the Internal Revenue Code (Decision Letters).2 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 they filed
the petition, petitioners resided in Loma Linda, California.
I. 1995
On July 12, 1999, respondent sent petitioner a notice of
deficiency addressed to petitioner at his last known address,
P.O. Box 1659, Loma Linda, CA 92354-1659, determining petitioner
owed an income tax deficiency of $269,251 and a penalty under
section 6662(a) in the amount of $53,850.20 for the 1995 tax
year. Petitioner did not respond to the notice of deficiency by
petitioning the Tax Court within 90 days from July 12, 1999.
On November 2, 2000, respondent filed a Notice of Federal
Tax Lien with respect to petitioner concerning the 1995 tax year.
1 When we refer to petitioner in the singular, we are
referring to petitioner Felix Prakasam.
2 Unless otherwise indicated, all section references are to
the Internal Revenue Code as amended.
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