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only swear to having "zero" income for 1998.
On June 14, 1999, respondent paid petitioner the $4,704.60
refund that she claimed in her 1998 return plus interest thereon.
On February 4, 2000, respondent issued to petitioner a
notice of deficiency (notice) with respect to her taxable year
1998, which she received. In that notice, respondent determined
a deficiency in, and an accuracy-related penalty under section
6662(a) on, petitioner’s tax for her taxable year 1998 in the
respective amounts of $5,969 and $1,177.
Petitioner did not file a petition in the Court with respect
to the notice relating to her taxable year 1998. Instead, on
April 15, 2000, in response to the notice, petitioner sent a
letter (petitioner’s April 15, 2000 letter) to the Internal
Revenue Service. That letter stated in pertinent part:
Your Deficiency Notice dated February 4, 2000.
First and foremost, be advised that this alleged
deficiency has been created out of thin air by the IRS
from a return which I submitted in a timely manner, a
return which was reviewed by the IRS and a refund
issued, including interest paid for the delay in re-
funding the amount to me. The IRS now attempts to
extort penalties and interest on top of the amount duly
refunded to me.
According to your “Deficiency Notice” of the above
date (cover sheet [page 1 of notice with respect to
petitioner’s taxable year 1998] attached), there is an
alleged deficiency with respect to my 1998 income tax
return of $7546.09, and if I wanted to “contest this
deficiency before making payment,” I must “file a
petition with the United States Tax Court.” Before I
file, pay, or do anything with respect to your “Notice”
I must first establish whether or not it was sent
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