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In February 1996, after various meetings with respondent’s
agents, petitioner submitted his delinquent returns for 1987
through 1991. Petitioner’s cover letter dated February 23, 1996,
and addressed to respondent’s revenue agent, alluded to personal
problems in petitioner’s family as the reason for the untimely
filings and concluded: “Again, thank you for your
professionalism and patience in the above matter during, and as a
result of the difficulties we have faced”.
On March 19, 1996, respondent issued a 30-day letter,
proposing adjustments to petitioner’s taxes for 1987 through
1991. By letter dated March 20, 1996, petitioner protested the
proposed adjustments.
On September 16, 1998, after consideration of petitioner’s
case by the Appeals Office, respondent issued to petitioner a
notice of deficiency for 1987 through 1991. On December 14,
1998, petitioner filed a petition in this Court, seeking
redetermination of the proposed deficiencies and additions to
tax. On November 5, 1999, pursuant to the parties’ stipulation,
this Court entered its decision in the deficiency case, deciding
that petitioner had deficiencies of $2,413, $12,000, and $4,000,
for 1987, 1990, and 1991, respectively, and had no deficiencies
or overpayments for 1988 and 1989. Petitioner did not appeal
this decision.
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