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Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
For purposes of the instant cross-motions for summary
judgment, and the respective objections thereto, the record
consists of documents set forth in respondent’s administrative
file, the pleadings filed herein, and the parties’ cross-motions
for summary judgment and attachments thereto.
Background
Respondent seeks to levy on petitioner’s property in
connection with petitioner’s assessed and outstanding 1992 and
1993 Federal income taxes and related additions to tax and
interest as follows:
Additions to Tax
Sec. Sec. Sec.
Year Deficiency 6651(a)(1) 6651(a)(3) 6654 Interest*
1992 $ 7,513 $1,878 $1,878 $327 $13,505
1993 10,460 2,615 2,615 441 16,620
* As of approximately Dec. 24, 2004. Includes
for 1992 an $18 collection fee.
Petitioner, who describes himself as “from the mountains” of
California, failed to file his 1992 and 1993 individual Federal
income tax returns.
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Last modified: May 25, 2011