- 3 -
On August 26, 2002, respondent assessed petitioner’s tax, as
well as additions to tax and interest as provided by law, for
each of his taxable years 1995, 1996, 1997, 1999, and 2000. (We
shall refer to any such unpaid assessed amounts, as well as
interest as provided by law accrued after August 26, 2002, as
petitioner’s unpaid liabilities for 1995, 1996, 1997, 1999, and
2000.)
On January 9, 2003, respondent received from petitioner
and Debra A. Evangelista (Ms. Evangelista) Forms 1040, U.S.
Individual Income Tax Return (Form 1040), for taxable years 1996
(petitioner’s3 Form 1040 for 1996), 1997 (petitioner’s Form 1040
for 1997), 1999 (petitioner’s Form 1040 for 1999), and 2000
(petitioner’s Form 1040 for 2000). On January 13, 2003, respon-
dent received from petitioner and Ms. Evangelista Form 1040 for
taxable year 1995 (petitioner’s Form 1040 for 1995).
On October 30, 2003, in response to petitioner’s Form 1040
for 1995, petitioner’s Form 1040 for 1996, petitioner’s Form 1040
for 1997, petitioner’s Form 1040 for 1999, and petitioner’s Form
1040 for 2000, respondent sent petitioner separate letters with
respect to such respective years (respondent’s October 30, 2003
letters). Each of those letters stated in pertinent part:
3This case involves only petitioner, and not Ms.
Evangelista. For convenience, we shall sometimes refer only to
petitioner, and not to petitioner and Ms. Evangelista.
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