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case. This case is before the Court on respondent’s Motion for
Summary Judgment pursuant to Rule 121.
Background
This case was commenced in response to a Notice of
Determination Concerning Collection Action(s) Under Section 6320
and/or 6330, sustaining the filing of a Notice of Federal Tax
Lien in order to collect petitioner’s unpaid Federal income taxes
for 1999 and 2000.
Petitioner filed his income tax return for 1999 and received
a refund of $24,228. For the 2000 taxable year, petitioner filed
his Federal income tax return and received refunds of $16,733 and
$500, respectively.
An audit occurred on January 7, 2003, and subsequently
respondent mailed a notice of deficiency to petitioner in which
respondent determined deficiencies in petitioner’s Federal income
taxes for taxable years 1999 and 2000 in the amounts of $20,764
and $24,532, respectively, together with accuracy-related
penalties pursuant to section 6662 for 1999 and 2000 in the
amounts of $4,152.80 and $4,906.40, respectively.
The notice of deficiency was mailed to petitioner at the
following addresses: 11705 Fishing River Road, Liberty, Missouri,
64068, and Post Office Box 100, Liberty, Missouri, 64069. Copies
of the notice of deficiency were also sent to petitioner’s
authorized representative, Richard T. Jones, at the following
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