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Background
This is an appeal from respondent’s determination to proceed
with the collection of petitioner’s 1990, 1991, 1992, 1993, and
1999 Federal income tax liabilities.2 Petitioner resided in
Redondo Beach, California, when his petition was filed.
Petitioner failed to file Federal income tax returns for
1990, 1991, 1992, and 1993. Respondent prepared substitutes for
returns under section 6020(b) for 1990, 1991, 1992, and 1993.
Respondent subsequently determined a deficiency in petitioner’s
tax liability for each of these years.
On April 14, 1995, respondent mailed to petitioner a notice
of deficiency for 1990 and 1991. Respondent sent the notice to
the following address: S. A. D’ONOFRIO, ORANGE COUNTY, C/O 676
CATALINA, AKA LAGUNA BEACH, CALIFORNIA. Petitioner refused to
accept delivery of the notice, and on April 20, 1995, respondent
received the returned notice of deficiency with the words
“Refused for Cause UCC 3-501” handwritten on the envelope. On
April 20 and September 13, 1995, respondent received letters from
petitioner marked “REFUSAL FOR CAUSE UCC 3-501 Without Dishonor”
in which petitioner raised various frivolous arguments regarding
2Respondent’s motion for partial summary judgment pertains
only to tax years 1990 through 1993. Respondent concedes that
petitioner did not have a prior opportunity to contest his
underlying tax liability for 1999. Accordingly, respondent
concurrently filed a motion for continuance so that he could have
an opportunity to resolve petitioner’s 1999 liability. On Feb.
5, 2007, we granted respondent’s motion for continuance.
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Last modified: March 27, 2008