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acknowledging receipt of the notice of deficiency dated August
20, 1999, but challenging the Director’s authority “to send me
the Notice in the first place.”
Petitioner knew that he had the right to contest
respondent’s deficiency determination by filing a petition for
redetermination with this Court.4 However, petitioner chose not
to do so. Accordingly, on February 7, 2000, respondent assessed
the determined deficiency, addition to tax, and accuracy-related
penalty, as well as statutory interest. On that same day,
respondent sent petitioner and his wife a notice of balance due,
informing them that they had a liability for 1997 and requesting
that they pay it. By letter dated March 4, 2000, petitioner
acknowledged receipt of this notice, but failed to pay the amount
owing.
On March 13, 2000, respondent sent petitioner and Carey Crow
a second notice of balance due for 1997. By letter dated March
17, 2000, petitioner acknowledged receipt of this second notice,
but failed to pay the amount owing.
4 In this regard, the first sentence of petitioner’s letter
dated Sept. 29, 1999, stated as follows:
According to your “Deficiency Notice” of 8-20-99
(attached), there is an alleged deficiency with respect
to my 1997 income tax of $4,031.00, and if I wanted to
“contest this deficiency before making payment,” I must
“file a petition with the United States Tax Court.”
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