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of $5,509, $3,673, $3,811 for 1996, 1997, 1998, respectively, and
6654(a) of $1,173, $786, $698 for 1996, 1997, 1998, respectively.
In response to respondent’s notices of deficiency,
petitioner filed a petition with this Court in Chang v.
Commissioner, docket No. 5674-01. The Court dismissed
petitioner’s case for lack of prosecution and entered a decision
on June 25, 2002, which held that petitioner was liable for the
income tax deficiencies along with additions to tax for 1996,
1997, and 1998. On December 9, 2002, respondent assessed the
deficiencies along with additions to tax and interest for 1996,
1997, and 1998.
Petitioner also failed to file Federal income tax returns
for 1999, 2000, 2001, and 2002 and did not make estimated tax
payments for these years. Respondent filed substitutes for
return on July 14, 2003, for 1999, 2000, and 2001 and filed a
substitute for return on June 28, 2004, for 2002. On October 10,
2003, respondent mailed petitioner three notices of deficiency
determining income tax deficiencies of $16,604, $28,482, and
$17,084 for 1999, 2000, 2001, respectively, and additions to tax
under sections 6651(a) of $4,151, $7,121, $4,271 for 1999, 2000,
2001, respectively, and 6654(a) of $804, $1,521, $683 for 1999,
2000, 2001, respectively. On July 27, 2004, respondent mailed
petitioner a notice of deficiency determining an income tax
deficiency of $12,976 and additions to tax under sections
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