Curtis B. Keene - Page 8




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          wages ($26,374), nonemployee compensation ($2,272), and                     
          unemployment compensation ($473).                                           
               By certified letters each dated September 16, 2000,                    
          petitioner wrote to respondent’s Service Center in Ogden, Utah,             
          acknowledging receipt of each of the notices of deficiency dated            
          June 16, 2000, but questioning, inter alia, “whether or not you             
          had any authority to even send me this ‘deficiency notice’” and             
          asking that “you identify which code section it is that                     
          establishes the tax liability upon which you determined these               
          * * * deficiencies.”  In his letters, petitioner also asserted              
          that “It is clear that your Notice of Deficiency is incorrect,              
          illegitimate and most likely fraudulent * * * .”                            
               Petitioner knew that he had the right to contest                       
          respondent’s deficiency determinations for 1997 and 1998 by                 
          filing a petition for redetermination with this Court.4  However,           
          petitioner chose not to do so.  Accordingly, on October 30, 2000,           
          respondent assessed the determined deficiencies, addition to tax,           
          and accuracy-related penalties, as well as statutory interest.              
          On that same day, respondent sent petitioner and his wife a                 

               4  In this regard, each of petitioner’s letters dated Sept.            
          16, 2000, stated as follows:                                                
               I recently received a “Deficiency Notice” dated June                   
               16th, 2000  * * * .  According to you there is an                      
               alleged deficiency with respect to this tax period                     
               * * * .  You also stated that IF, I wanted to “contest                 
               this deficiency before making payment,” then I must                    
               “file a petition with the United States Tax Court.”                    





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