Paul L. Bowman - Page 2




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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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