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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
1998.
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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