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Petitioner resided in Brooklyn, New York, at the time he
filed the petition in this case.
Petitioner did not file a Federal income tax (tax) return
for each of his taxable years 2000, 2001, and 2002.
On August 10, 2004, respondent issued to petitioner a notice
of deficiency with respect to his taxable year 2002 (2002 no-
tice), which he received. In that notice, respondent determined
the following deficiencies in, and additions to, petitioner’s
tax:
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6651(a)(1)1 6651(a)(2) 6654
2002 $53,753 $3,704.40 $1,811.04 $411.70
On September 14, 2004, respondent issued to petitioner a notice
of deficiency with respect to his taxable years 2000 and 2001
(2000 and 2001 notice), which he received. In that notice,
respondent determined the following deficiencies in, and addi-
tions to, petitioner’s tax:
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6651(a)(2) 6654
2000 $43,959 $4,631.17 $4,837.00 $967.34
2001 35,660 3,294.22 2,562.17 486.97
1All section references are to the Internal Revenue Code in
effect at all relevant times. All Rule references are to the Tax
Court Rules of Practice and Procedure.
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