Kevin M. Moore - Page 3




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                                  FINDINGS OF FACT                                    
               Accordingly, pursuant to Rule 91(f), the facts set forth in            
          the Rule 91(f) motion are deemed stipulated and are so found.               
          The stipulation of facts and the attached exhibits are                      
          incorporated herein by this reference.  At the time he filed the            
          petition, petitioner resided in Tampa, Florida.                             
               Petitioner failed to timely file Federal income tax returns            
          for 1997, 1998, 1999, 2000, 2001, and 2002.  On October 17, 2003,           
          respondent sent petitioner statutory notices of deficiency for              
          1997, 1999, and 2000.  On February 4, 2004, respondent sent                 
          petitioner a statutory notice of deficiency for 2001.  Respondent           
          determined deficiencies in and additions to petitioner’s Federal            
          income tax as follows:2                                                     
                  Additions to Tax                                                    
          Year    Deficiency    Sec. 6651(a)(1)    Sec. 6654(a)                       
               1997     $52,911         $11,905            $2,851                     
               1999      28,242           5,454             1,294                     
               2000      53,465          12,030             2,876                     
               2001      51,134          15,852             2,024                     
          Petitioner received the notices of deficiency and chose not to              
          petition this Court.                                                        
               On March 29, 2006, respondent sent petitioner a Final                  
          Notice--Notice of Intent to Levy and Notice of Your Right to a              
          Hearing with respect to petitioner’s 1997, 1998, 1999, 2000,                
          2001, and 2002 taxable years (levy notice).  The levy notice                


               2  Amounts are rounded to the nearest dollar.                          





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