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MEMORANDUM FINDINGS OF FACT AND OPINION
WHERRY, Judge: This case is before the Court on a petition
for judicial review of a Notice of Determination Concerning
Collection Action(s) Under Section 6320 and/or 6330. The issues
for decision are: (1) Whether respondent may proceed with
collection action as so determined; and (2) whether the Court
should sua sponte impose a penalty pursuant to section 6673(a).1
FINDINGS OF FACT
Some of the facts have been stipulated and are so found.
The stipulations of the parties, with accompanying exhibits, are
incorporated herein by this reference. At the time this petition
was filed, petitioner resided in Muskegon, Michigan.
For the 1999 and 2000 taxable years, petitioner submitted to
the Internal Revenue Service (IRS) Forms 1040, U.S. Individual
Income Tax Return, that contained entirely zeros. On October 2,
2002, respondent issued to petitioner a notice of deficiency for
the 2000 taxable year showing a deficiency of $19,566 and a
penalty pursuant to section 6662(a) and (b)(1) of $3,913.20. On
November 27, 2002, respondent issued to petitioner a notice of
deficiency for the 1999 taxable year that showed a deficiency of
$14,611 and additions to tax pursuant to sections 6651(a)(1) and
6654(a) of $3,294.55 and $630.07, respectively. Petitioner,
1Unless otherwise indicated, all section references are to
the Internal Revenue Code (Code) of 1986, as amended.
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Last modified: May 25, 2011