- 2 -
The petition in this case was filed in response to a Notice
of Determination Concerning Collection Action(s) Under Section
6320 and/or 6330 (notice of determination) for 1996, 1997, 1998,
and 1999. Petitioner does not dispute the amount of the
underlying taxes and interest owed for the years in issue. What
petitioner does dispute is his liability for the additions to tax
under section 6651(a)(1) for failure to timely file returns,
section 6651(a)(2) for failure to timely pay the unpaid tax
reported on the returns, and section 6654 for failure to pay
estimated taxes.
Background
The stipulated facts and the exhibits received into evidence
are incorporated herein by reference. At the time the petition
in this case was filed, petitioner resided in Stockton,
California.
Petitioner filed Federal tax returns for each year in issue
reporting taxes due as follows:
Year Date Due Date Filed Tax Due
1996 10/15/97 06/12/98 $4,737
1997 10/15/98 04/10/99 3,644
1998 10/15/99 02/24/00 7,162
1999 08/15/00 04/10/01 2,079
At the time petitioner filed each return, he either did not
pay or made only small payments toward the amounts shown as taxes
on the returns. Respondent assessed the amounts reported on
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011