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deficiency of $3,990 on the unreported income from Legg Mason.
The notice was sent by certified mail, and respondent’s file
indicates that the notice was not returned. Petitioner claims
that he did not receive the notice, and no petition for a
redetermination was filed with this Court. By letter dated May
14, 1999, however, petitioner wrote respondent stating: “we do
not admit that the Legg Mason interest amounts are due”. He
further stated that he disputed the interest and penalties
because “the IRS did not notify us in a timely manner thereby
causing us to be infected [sic] with the said penalties and
interest.”
On or about August 23, 1999, petitioner sent a Form 843,
Claim for Refund and Request for Abatement, to respondent
requesting that the $3,990 deficiency, penalties, and interest be
abated. He alleged that the interest was caused by respondent’s
“errors or delays” and that the “penalty or addition to tax * * *
[was the] result of erroneous advice from the IRS.”
Although the record does not reveal the date, apparently at
some time subsequent, respondent assessed the deficiency. On
February 9, 2000, petitioner sent another Form 843 to respondent
seeking an abatement of the penalties and interest only. By
letter dated April 6, 2000, petitioner was notified by the
District Director that his request for abatement had been
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