Anthony M. Davich - Page 6




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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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