Michael Stein, (2004)
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Michael Stein, (2004)
T.C. Memo. 2004-124
UNITED STATES TAX COURT MICHAEL STEIN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10970-01L. Filed May 24, 2004.Michael Stein, pro se.John Aletta, for respondent.MEMORANDUM OPINION BEGHE, Judge: Petitioner failed to file timely Federal income tax returns for 1992, 1993, and 1994. Respondent filed 'substitutes for return'1 (SFRs) for those years, mailed petitioner statutory notices of deficiency to which he never responded, and thereafter assessed income tax liabilities against petitioner for those years.As of March 8, 1999, petitioner's total unpaid tax liabilities for the above-mentioned years, including the unpaid assessed income tax liabilities, and additions to tax and interest, were as follows:Unpaid Additions to Tax Total Unpaid Year Assessments and/or Interest Liabilities 1992 $1,344.17 $1,068.95 $2,413.121993 5,505.15 1,910.12 7,415.271994 197,079.49 63,903.26 260,982.75On February 23, 2000, respondent filed a notice of Federal tax lien (NFTL) against petitioner's real property with respect to $203,928.81, the then-unpaid balance of petitioner's 1992 through 1994 tax liabilities. On July 26, 2001, respondent issued petitioner a notice of determination concerning collection action(s) under section 6320 and/or 6330,2 which upheld respondent's NFTL.3 The issues for decision presented by petitioner's timely filed petition with this Court are: 1. Whether petitioner is liable for the deficiencies assessed by respondent. We hold petitioner is liable for the deficiencies because petitioner has not satisfied the conditions that would entitle him in this proceeding to contest respondent's deficiency determinations or assessments; and...See the full content of this document
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