- 3 - Petitioner did not file a petition with the Court with respect to the 2002 notice or the 2000 and 2001 notice.2 On February 7, 2005, respondent assessed petitioner’s tax, as well as additions to tax and interest as provided by law, for his taxable year 2002. (We shall refer to those unpaid assessed amounts, as well as interest as provided by law accrued after February 7, 2005, as petitioner’s unpaid liability for 2002.) On February 7, 2005, respondent issued to petitioner the notice and demand for payment required by section 6303(a) with respect to petitioner’s unpaid liability for 2002. On February 21, 2005, respondent assessed petitioner’s tax, as well as additions to tax and interest as provided by law, for each of his taxable years 2000 and 2001. (We shall refer to those unpaid assessed amounts, as well as interest as provided by law accrued after February 21, 2005, as petitioner’s unpaid liabilities for 2000 and 2001.) On February 21, 2005, respondent issued to petitioner the notice and demand for payment required by section 6303(a) with respect to petitioner’s unpaid liabilities for 2000 and 2001. On September 20, 2005, respondent filed a notice of Federal 2Form 4340, Certificate of Assessments, Payments, and Other Specified Matters (Form 4340), with respect to petitioner’s taxable year 2002 indicates that the 2002 notice was “closed” on Dec. 28, 2004. Form 4340 with respect to each of petitioner’s taxable years 2000 and 2001 indicates that the 2000 and 2001 notice was “closed” on Feb. 1, 2005.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 NextLast modified: November 10, 2007