- 2 - determining that a Federal tax lien was appropriately imposed on petitioner’s property with respect to tax owed for tax years 1991, 1992, and 1993. Background At the time petitioner filed the petition, he resided in Pasadena, Texas. Petitioner failed to file Federal income tax returns for the tax years 1991, 1992, and 1993. Consequently, respondent prepared a substitute for return for each of those years. On May 6, 1997, respondent issued a notice of deficiency, determining deficiencies of $14,823 for 1991, $33,329 for 1992, and $25,502 for 1993. Respondent also determined that petitioner was liable for additions to tax under sections 6651(a)(1) and 6654 of $2,508 for 1991, $8,279 for 1992, and $7,222 for 1993. Petitioner did not judicially challenge these determinations.2 On October 29, 1997, respondent assessed tax and additions to tax for tax years 1991, 1992, and 1993 as shown in the notice of deficiency, as well as interest thereon. On January 14, 2004,3 respondent mailed petitioner a Final Notice of Intent to Levy and 2Petitioner’s response to the notice of deficiency was to retain an attorney, J. Hamilton McMenamy, who, acting on behalf of petitioner, sent a letter to respondent dated July 11, 1997, raising frivolous arguments in regard to the notice of deficiency. For example, the letter demanded to know what Code section imposes a tax on petitioner and the specific tax forms petitioner was required to file to report his tax. The letter suggested that petitioner had no duty to pay taxes. 3It appears that petitioner may have filed for bankruptcy at some point during the 1997-2004 interim.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 NextLast modified: November 10, 2007