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On November 13, 1998, respondent received a letter (dated
November 8, 1998) from petitioners acknowledging receipt of the
notices of deficiency dated September 11, 1998, and challenging
their validity. Petitioners did not file a petition for
redetermination with the Court challenging the notices of
deficiency dated September 11, 1998.
On March 12, 1999, respondent issued a joint notice of
deficiency to petitioners. In the notice, respondent determined
a deficiency in the amount of $12,049 in petitioners’ Federal
income tax for 1997 and an accuracy-related penalty under section
6662(a) in the amount of $1,899.31. The deficiency in income tax
was based on respondent’s determination that petitioners failed
to report wage income, interest and dividends, capital gain, and
an IRA distribution.
On April 9, 1999, respondent received a letter (dated March
25, 1999) from petitioners acknowledging receipt of the notice of
deficiency dated March 12, 1999, and challenging its validity.
Petitioners did not file a petition for redetermination with the
Court challenging the notice of deficiency dated March 12, 1999.
Respondent subsequently made assessments against petitioners
for the deficiencies, additions to tax, and accuracy-related
penalties determined in the above-described notices of
deficiency. Respondent also made assessments against petitioners
for statutory interest. On the same day that the assessments
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