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Background
The record establishes and/or the parties do not dispute the
following.
Petitioner resided in Massapequa, New York, at the time he
filed the petition in this case.
On June 10, 2002, respondent issued to petitioner a notice
of deficiency (notice) with respect to his taxable years 1995 and
1998, which he received. In that notice, respondent determined
deficiencies in, and additions to, petitioner’s Federal income
tax (tax) for each of his taxable years 1995 and 1998, as fol-
lows:
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6651(a)(1)2 6651(a)(2) 6654
1995 $13,063 $2,939 $3,266 $708
1998 23,239 5,229 3,602 1,063
On August 22, 2002, petitioner submitted a document to the
Court with respect to the notice relating to his taxable years
1995 and 1998 that the Court had filed as a petition and that
commenced the case at docket No. 14560-02. On September 16,
2002, the Court issued an Order in that case (September 16, 2002
Order in the case at docket No. 14560-02) ordering petitioner to
file a proper amended petition in the form enclosed with that
2All 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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Last modified: November 10, 2007