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T.C. Memo. 2007-237 UNITED STATES TAX COURT RICHARD FRANSEN, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 8682-06L. Filed August 20, 2007. Richard Fransen, pro se. Marie E. Small, for respondent. MEMORANDUM OPINION CHIECHI, Judge: This case is before the Court on respon- dent’s motion for summary judgment (respondent’s motion). We shall grant respondent’s motion. Background The record establishes and/or the parties do not dispute the following. - 2 - Petitioner resided in Brooklyn, New York, at the time he filed the petition in this case. Petitioner did not file a Federal income tax (tax) return for each of his taxable years 2000, 2001, and 2002. On August 10, 2004, respondent issued to petitioner a notice of deficiency with respect to his taxable year 2002 (2002 no- tice), which he received. In that notice, respondent determined the following deficiencies in, and additions to, petitioner’s tax: Additions to Tax Sec. Sec. Sec. Year Deficiency 6651(a)(1)1 6651(a)(2) 6654 2002 $53,753 $3,704.40 $1,811.04 $411.70 On September 14, 2004, respondent issued to petitioner a notice of deficiency with respect to his taxable years 2000 and 2001 (2000 and 2001 notice), which he received. In that notice, respondent determined the following deficiencies in, and addi- tions to, petitioner’s tax: Additions to Tax Sec. Sec. Sec. Year Deficiency 6651(a)(1) 6651(a)(2) 6654 2000 $43,959 $4,631.17 $4,837.00 $967.34 2001 35,660 3,294.22 2,562.17 486.97 1 All section references are to the Internal Revenue Code in effect at all relevant times. All Rule references are to the Tax Court Rules of Practice and Procedure. - 3 - Petitioner did not file a petition with the Court with respect to the 2002 notice or the 2000 and 2001 notice.2 On February 7, 2005, respondent assessed petitioner’s tax, as well as additions to tax and interest as provided by law, for his taxable year 2002. (We shall refer to those unpaid assessed amounts, as well as interest as provided by law accrued after February 7, 2005, as petitioner’s unpaid liability for 2002.) On February 7, 2005, respondent issued to petitioner the notice and demand for payment required by section 6303(a) with respect to petitioner’s unpaid liability for 2002. On February 21, 2005, respondent assessed petitioner’s tax, as well as additions to tax and interest as provided by law, for each of his taxable years 2000 and 2001. (We shall refer to those unpaid assessed amounts, as well as interest as provided by law accrued after February 21, 2005, as petitioner’s unpaid liabilities for 2000 and 2001.) On February 21, 2005, respondent issued to petitioner the notice and demand for payment required by section 6303(a) with respect to petitioner’s unpaid liabilities for 2000 and 2001. On September 20, 2005, respondent filed a notice of Federal 2 Form 4340, Certificate of Assessments, Payments, and Other Specified Matters (Form 4340), with respect to petitioner’s taxable year 2002 indicates that the 2002 notice was “closed” on Dec. 28, 2004. Form 4340 with respect to each of petitioner’s taxable years 2000 and 2001 indicates that the