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On November 22, 2003, respondent issued petitioner a notice
of deficiency, which petitioner received. Respondent determined
the following deficiencies in Federal income tax, additions to
tax under section 6651(a)(1) for failure to timely file returns,
and penalties under section 6663 for civil tax fraud:
Year Tax Additions to tax Penalties
Sec. 6651(a)(1) Sec. 6663
1995 $9,158 $2,290 $6,869
1996 9,496 2,374 7,122
1997 5,033 1,258 3,775
1998 3,245 811 2,434
1999 1,666 417 1,250
2000 3,544 886 2,658
Petitioner did not file a petition with this Court in response to
the notice of deficiency.
On March 22, 2004, respondent assessed the tax due, the
additions to tax, and the penalties for the years at issue. On
the same day, respondent issued petitioner a notice of balance
due and demand for payment.
2(...continued)
petitioner requested to cross-examine the parties who submitted
documentation in response to the summonses. Respondent denied
petitioner’s request. Respondent also denied petitioner’s
request that the examining officer submit a request for technical
advice regarding the cross-examination issue to respondent’s
National Office.
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Last modified: November 10, 2007