Said Jumaa - Page 2

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               Petitioner resided in Ottumwa, Iowa, at the time he filed              
          the petition in this case.                                                  
               Petitioner did not timely file a Federal income tax (tax)              
          return for his taxable year 1998.                                           
               On March 12, 2001, respondent mailed to petitioner at his              
          last known address a notice of deficiency with respect to his               
          taxable year 1998.  In that notice, respondent determined the               
          following deficiency in, and additions to, the tax of petitioner:           
                                     Additions to Tax                                 
                                        Sec.           Sec.         Sec.              
              Year      Deficiency   6651(a)(1)1   6651(a)(2)       6654              
              1998       $159,289    $35,840.02    $14,336.01    $7,229.64            
               Petitioner did not file a petition with the Court with                 
          respect to the notice of deficiency relating to his taxable year            
               On August 6, 2001, respondent assessed petitioner’s tax, as            
          well as additions to tax and interest as provided by law, for his           
          taxable year 1998.  (We shall refer to any such unpaid assessed             
          amounts, as well as interest as provided by law accrued after               
          August 6, 2001, as petitioner’s unpaid liability for 1998.)                 
               On August 6, 2001, respondent issued to petitioner the                 
          notice and demand for payment required by section 6303(a) with              
          respect to petitioner’s unpaid liability for 1998.                          

               1All 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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