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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
decision.
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
separately.
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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