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66821 penalty. After the petition was filed, respondent moved to
dismiss the section 6682 penalty for lack of this Court’s
jurisdiction. The issues for our consideration are as follows:
(1) Whether we have jurisdiction over the portion of the petition
that relates to the section 6682 penalty, and (2) whether
respondent’s determination to proceed with collection of
petitioner’s assessed income tax for 1996 was an abuse of
discretion.
FINDINGS OF FACT
Petitioner, who resided in Bethel Park, Pennsylvania, at the
time his petition was filed, did not file a 1996 Federal income
tax return. Respondent examined petitioner’s 1996 tax year by
means of correspondence. In response to respondent’s
correspondence, petitioner protested the deficiency and requested
an interview.
On December 15, 1997, respondent mailed petitioner a
statutory notice determining an $11,172.81 income tax deficiency
for 1996. Petitioner sent a letter to this Court concerning the
deficiency notice. Petitioner’s letter was filed as a petition,
and he was notified that to perfect it, he had to provide
additional information and pay a $60 filing fee. In response,
petitioner sent a letter to this Court stating that no deficiency
1 Unless otherwise indicated, all section references are to
the Internal Revenue Code.
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