Clyde E. Hack and Carole J. Hack - Page 3




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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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