- 3 - Background Some of the facts have been stipulated and are so found. The stipulation of facts and the exhibits received into evidence are incorporated herein by reference. At the time the petition was filed, petitioner resided in Somerville, Massachusetts. Petitioner is a high school graduate who was employed in clerical positions during the years at issue. Petitioner and Joseph J. Lepordo filed a joint Form 1040, U.S. Individual Income Tax Return, for each of the years at issue. The Federal income tax returns for 1996 and 1999 showed tax due in excess of the remittances. For 1998, 2001, and 2002, the Federal income tax returns were filed without remittances for the tax reported. With respect to 2000, respondent determined a $17,701 deficiency in the notice of deficiency mailed to petitioner and Mr. Lepordo on August 9, 2002. The deficiency was assessed when they failed to file a petition with the Court. The taxable years and the tax due for each year are summarized as follows: Year Tax before credits 1996 $8,598 1998 14,508 1999 13,871 2000 17,701 2001 18,089 2002 15,484 On April 21, 2003, the Internal Revenue Service (IRS) issued to petitioner and Mr. Lepordo a notice of intent to levy with respect to 1996. On September 9, 2003, petitioner and Mr.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008