- 6 - account. See sec. 6211(b)(1). The deficiencies in income taxes were based on respondent’s determination that petitioner failed to report income determined as follows: 1997 1998 Wages $26,319 $53,945 Interest income 236 53 Nonemployee compensation --- 125 26,555 54,123 By certified letter dated March 3, 2000, petitioner wrote to respondent’s district office in Phoenix, Arizona, acknowledging receipt of the notice of deficiency dated December 8, 1999, but challenging respondent’s authority “to send me the ‘Notice’ in the first place.” Petitioner sent copies of his letter by certified mail to Lawrence H. Summers, Secretary of the Treasury, and Charles O. Rossotti, Commissioner of Internal Revenue. Petitioner knew that he had the right to contest respondent’s deficiency determinations by filing a petition for redetermination with this Court.2 However, petitioner chose not to do so. Accordingly, on May 8, 2000, respondent assessed the 2 In this regard, petitioner’s letter dated Mar. 3, 2000, stated as follows: According to your “Deficiency Notice”, dated December 8, 1999 (cover sheet attached), there is an alleged deficiency with respect to my 1997 and 1998 income taxes of $3,559.00 and $12,393.00, respectively, and if I wanted to “contest this determination... before making payment,” I must “file a petition with the United States Tax Court.”Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011