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SUPPLEMENTAL MEMORANDUM OPINION
WHERRY, Judge: The petition in this case was filed in
response to a Notice of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330.1 The matter is
presently before the Court on respondent’s motion for imposition
of a penalty under section 6673.
Background
Relevant background information may be summarized as
follows. Petitioner failed to file Federal income tax returns
for the 1987 to 1992 taxable years. On May 9, 1994, the Internal
Revenue Service (IRS) issued to petitioner a statutory notice of
deficiency for those years. Petitioner at no time alleged that
he did not receive the notice.
No petition was filed with the Tax Court in response to the
May 9, 1994, notice, and the deficiencies and additions to tax
determined therein, as well as statutory interest, were assessed
on November 14, 1994. Notices of balance due were sent to
petitioner for all years on that date and on December 19, 1994,
January 23, 1995, and February 27, 1995.
Respondent subsequently issued to petitioner with respect to
his 1987 through 1992 income tax liabilities a Final Notice of
1 Unless otherwise indicated, section references are to the
Internal Revenue Code of 1986, as amended.
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