John B. Cosgriff - Page 3

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          included the disallowance of petitioner’s Schedule C business               
          loss, the inclusion of certain royalties in income, and the                 
          imposition of late-filing and accuracy-related penalties.                   
          Thereafter, two appointments were scheduled between petitioner              
          and respondent’s agent to discuss the 1992 return, but petitioner           
          canceled both appointments.  On April 19, 1995, respondent                  
          notified petitioner that respondent’s previous proposed                     
          determinations had not changed.  On July 26, 1995, a notice of              
          deficiency was sent to petitioner determining a $2,483                      
          deficiency, a $42 late-filing penalty, and a $497 accuracy-                 
          related penalty.  Petitioner did not file a petition with this              
          Court seeking a redetermination of the deficiency and penalties,            
          and the amounts determined in the notice of deficiency were                 
               On October 31, 1995, petitioner requested reconsideration of           
          respondent’s determination, but the request was denied because              
          petitioner had failed to timely contest the notice of deficiency.           
          On February 13, 1996, petitioner called a problem resolution                
          officer at the Ogden Service Center to request a review of his              
          1992 tax liability.  The Problem Resolution Office in the Ogden             
          Service Center reviewed the matter and, in a letter to petitioner           
          dated May 3, 1996, informed petitioner that a review of his                 
          account for 1992 indicated that the balance due was correct.  In            
          June of 1996, petitioner sent a letter to Senator Bryan of Nevada           

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