David M. Leggett - Page 11

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               After the March 1996 meeting, the revenue officer opened a             
          case file on petitioner.  The revenue officer never received from           
          petitioner a request for abatement of the civil penalties or his            
          delinquent returns for 1992, 1993, and 1994.  However, the                  
          revenue officer did receive on a date not disclosed by the record           
          a letter from petitioner in which he raised questions about who             
          has the authority to sign a return for him and about the Code of            
          Federal Regulations.  The revenue officer sent petitioner a                 
          response to that letter in which he informed petitioner (1) that            
          he had decided not to abate the civil penalties, since petitioner           
          had not provided him with reasonable cause for abating those                
          penalties, and (2) that petitioner had the right to appeal that             
               On May 28, 1997, respondent issued a notice of deficiency              
          (notice) to petitioner in which respondent determined, inter                
          alia, that petitioner is liable for the addition to tax under               
          section 6651(f) for fraudulent failure to file a return for each            
          of the years at issue.  In the notice, respondent determined that           
          petitioner's filing status for those years is married, filing               
               On April 30, 1998, the Service filed separate notices of               
          Federal tax lien with the Register of Deeds, Jackson County,                
          Gainsboro, Tennessee, in favor of the United States on all                  
          property and rights to property belonging to petitioner and Ms.             
          Leggett, respectively, for the civil penalties.                             

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