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Background
The record establishes and/or the parties do not dispute the
following.
Petitioner resided in Algona, Iowa, at the time he filed the
petition in this case.
Petitioner did not file a Federal income tax (tax) return
for each of his taxable years 2001 and 2002.
On June 15, 2004, respondent issued to petitioner a notice
of deficiency with respect to each of his taxable years 2001
(2001 notice of deficiency) and 2002 (2002 notice of deficiency),
both of which petitioner received. In the 2001 notice of defi-
ciency, respondent determined a deficiency in, and additions
under section 6651(a)(1)2 and 6651(a)(2) to, petitioner’s tax for
his taxable year 2001 in the respective amounts of $3,487.10,
$225.02, and $125.01.3 In the 2002 notice of deficiency, respon-
dent determined a deficiency in, and additions under sections
6651(a)(1), 6651(a)(2), and 6654 to, petitioner’s tax for his
taxable year 2002 in the respective amounts of $14,661,
2All section references are to the Internal Revenue Code in
effect at all relevant times. Unless otherwise indicated, all
Rule references are to the Tax Court Rules of Practice and
Procedure.
3With respect to the addition to tax under sec. 6651(a)(2),
respondent determined in the 2001 notice of deficiency that that
“addition to tax will continue to accrue from the due date of the
return at a rate of 0.5 percent each month, or fraction thereof,
of nonpayment, not exceeding 25 percent.”
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Last modified: November 10, 2007