Woodrow Reynolds - Page 2

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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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