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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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