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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.”
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