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from Pensions, Annuities, Retirement or Profit Sharing Plans,
IRAs, Insurance Contracts, etc. The Form 1099-R was from
Fidelity Investments and reported that it had made a $5,292.66
taxable distribution to Carole Hack and withheld from that
distribution Federal income tax of $1,058.53. The first Form W-2
was from Systems & Computer Tech and reported that it had paid to
Carole Hack $28,488.81 in wages and withheld from those wages
Federal income tax of $764.14. The second Form W-2 was from
Pilot Corporation and reported that it had paid to Clyde Hack
$34,307.50 in wages and withheld from those wages Federal income
tax of $147.13.
On February 18, 2000, respondent issued a notice of
deficiency to petitioners. The notice determined that
petitioners were liable for a $10,599.20 deficiency in their 1998
income tax and a $2,119.84 accuracy-related penalty under section
6662(a). Petitioners did not petition the Court with respect to
the notice. Instead, on March 4, 2000, petitioners sent to
respondent a letter entitled “Your Deficiency Notice dated
February 18, 2000.” 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
July 31, 2000, respondent assessed petitioners’ tax liability for
1998 as per the notice of deficiency.
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Last modified: May 25, 2011