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Petitioner submitted Forms 1040, U.S. Individual Income Tax
Return, for 1999 and 2000 to respondent. Petitioner listed zero
as the amount of his wages, total income, adjusted gross income,
taxable income, and total tax on both returns. Petitioner
attached two pages to the Forms 1040 reciting statements,
contentions, and arguments that the Court finds to be frivolous
and/or groundless.
Respondent sent petitioner statutory notices of deficiency
for the 1999 and 2000 tax years on December 21, 2001, and June
12, 2002, respectively. Respondent determined a $13,510
deficiency and a $2,701 penalty pursuant to section 6662(a)1 for
1999 and a $56,218 deficiency and a $11,243.60 penalty pursuant
to section 6662(a) for 2000. Petitioner received the notices of
deficiency and sent respondent letters challenging respondent’s
authority to issue the notices but did not petition the Court for
redetermination of the deficiencies or penalties with respect to
1999 or 2000. On September 16, 2002, and December 2, 2002,
respondent assessed the 1999 and 2000 tax liabilities and
penalties, respectively.
On November 20, 2003, respondent mailed to petitioner a
Final Notice of Intent to Levy and Notice of Your Right to a
Hearing concerning petitioner’s 1999 and 2000 liabilities. On or
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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Last modified: May 25, 2011