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Petitioner filed a petition with this Court in response to a
Notice of Determination Concerning Collection Action(s) Under
Section 6320 and/or 6330 (notice of determination) for 1990,
1997, 1999 (years at issue).1 Pursuant to section 6330(d),
petitioner seeks review of respondent’s determination. The issue
for decision is whether petitioner is entitled to any relief from
respondent’s determination that collection may proceed.
The parties’ stipulation of facts and the attached exhibits
are incorporated herein by this reference. Petitioner resided in
Honolulu, Hawaii, when he filed his petition.
Petitioner did not file a Federal income tax return for 1990
and did not make estimated tax payments for 1990. Respondent
filed a substitute for return on June 7, 1993. Respondent mailed
petitioner notices of deficiency for 1990 on June 25 and November
9, 1993, to two separate addresses, determining that petitioner
owed a deficiency of $2,598, as well as additions to tax under
sections 6651(a) and 6654(a) of $650 and $171, respectively.
Petitioner did not file a petition with the Court to redetermine
the deficiency. On August 15, 1994, respondent assessed the tax
liability including penalties and interest for 1990.
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code, as amended, and all Rule references
are to the Tax Court Rules of Practice and Procedure. Amounts
are rounded to the nearest dollar.
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Last modified: November 10, 2007