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FINDINGS OF FACT
Some of the facts have been stipulated. We incorporate the
stipulated facts into our findings by this reference. Petitioner
resided in Shrewsbury, Massachusetts, when his petition in this
case was filed.
Petitioner failed to file Federal income tax returns for
1996, 1997, 1998, and 2000. Respondent prepared substitute
returns pursuant to section 6020(b) and determined deficiencies
for all relevant years. Respondent mailed a notice of deficiency
dated April 19, 2002, for 1996, 1997, and 1998 to petitioner, and
petitioner received the notice.2 However, the record does not
disclose whether respondent mailed a notice of deficiency to
petitioner for 2000.
Petitioner failed to petition this Court regarding the
notice of deficiency for 1996, 1997, and 1998, and on March 3,
2003, respondent assessed tax deficiencies against petitioner for
1996, 1997, and 1998. Also, on March 3, 2003, respondent
assessed a tax deficiency against petitioner for 2000. For
reasons that are not explained in the record, in March 2003
respondent erroneously abated the deficiencies owed by petitioner
for 1996, 1997, and 1998. On April 21, 2003, respondent reversed
the abatement and reinstated the 1997 assessment, and on April
2 Petitioner attached a copy of this notice to his request
for a sec. 6330 hearing.
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