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Company Jobbers Inc. and reported that it had paid to Clyde Hack
$432 in wages and withheld from those wages Federal income tax of
$2.89. The second Form W-2 was from Systems & Computer Tech and
reported that it had paid to Carole Hack $35,438.46 in wages and
withheld from those wages Federal income tax of $6,374.45. The
third Form W-2 was from Pilot Corporation and reported that it
had paid to Clyde Hack $39,731.09 in wages and withheld from
those wages Federal income tax of $7,304.20.
On July 16, 1999, respondent issued a notice of deficiency
to petitioners. The notice determined that petitioners were
liable for a $15,404.30 deficiency in their 1997 income tax and a
$79.31 accuracy-related penalty under section 6662(a).
Petitioners did not petition the Court with respect to the
notice. Instead, on September 23, 1999, petitioners sent to
respondent a letter entitled “Your Deficiency Notice dated July
16, 1999.” Petitioners stated in this letter that the notice of
deficiency was invalid because it was not sent by the Secretary
and lacked a proper delegation of authority to the signatory;
i.e., the director of the Ogden Service Center. On February 28,
2000, respondent assessed petitioners’ tax liability for 1997 as
per the notice of deficiency.
On August 3, 2000, respondent mailed to petitioners a “Final
Notice - Notice of Intent to Levy and Notice of Your Right to a
Hearing” (final notice). The final notice informed petitioners
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