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By registered letter dated November 1, 2000, petitioner
wrote to the director of respondent’s Service Center in Ogden,
Utah, acknowledging receipt of the notice of deficiency dated
August 11, 2000, but challenging respondent’s authority “to send
me the Notice in the first place.” Petitioner sent copies of his
letter by registered mail to Lawrence H. Summers, Secretary of
the Treasury, and Charles O. Rossotti, Commissioner of Internal
Revenue.
Petitioner knew that he had the right to contest
respondent’s deficiency determination by filing a petition for
redetermination with this Court.3 However, petitioner chose not
to do so. Accordingly, on February 26, 2001, respondent assessed
the determined deficiency and accuracy-related penalty, as well
as statutory interest. On that same day, respondent sent
petitioner a notice of balance due, informing him that he had a
liability for 1998 and requesting that he pay it. Petitioner
failed to pay the amount owing.
3 In this regard, petitioner’s letter dated Nov. 1, 2000,
stated as follows:
According to your “Deficiency Notice” of above date
(cover sheet attached), there is an alleged deficiency
with respect to my 1998 income tax * * *, and if I
wanted to “contest this deficiency before making
payment, I must “file a petition with the United States
Tax Court.”
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