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Background
This is an appeal from respondent’s determination upholding
the proposed use of a levy to collect petitioner’s unpaid Federal
income tax liabilities for 1991 through 1998 and 2002.
Petitioner resided in Endicott, New York, when the petition in
this case was filed.
Petitioner failed to file Federal income tax returns for
1991 through 1998 and 2002. Under section 6020(b), respondent
prepared a substitute for return for each of the above years.
On September 14, 2004, respondent mailed petitioner a statutory
notice of deficiency for 2002, and on September 24, 2001,
respondent mailed petitioner a statutory notice of deficiency for
1991 through 1998. In the notices of deficiency, respondent
determined petitioner was liable for income tax deficiencies and
additions to tax for 1991 through 1998 and 2002.
Petitioner failed to petition this Court in response to the
above-mentioned notices of deficiency. On February 4, 2002,
respondent assessed the tax liabilities, additions to tax, and
interest for 1991 and 1992; on April 15, 2002, respondent
assessed the tax liabilities, additions to tax, and interest for
1993 through 1998; and on February 7, 2005, respondent assessed
the tax liabilities, additions to tax, and interest for 2002.
Respondent sent petitioner Notice and Demand with respect to each
of the assessed and unpaid liabilities.
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Last modified: November 10, 2007