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Stein v. Commissioner

Docket No. 10970-01L.

87 T.C.M. 1358 (2004)

T.C. Memo. 2004-124

Michael Stein v. Commissioner.

United States Tax Court.

May 24, 2004.

Attorney(s) appearing for the Case

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...

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