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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.
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Last modified: November 10, 2007