- 6 - disregard of rules or regulations in the amount of $4,408.02.3 The deficiency in income tax was based on respondent’s determination that petitioner failed to report income in the aggregate amount of $144,161, determined as follows: Income Amount Wages $111,180 Interest 160 Capital gain 22,591 Dividends 1,626 Social Security 8,604 144,161 By registered letter dated February 23, 2000, petitioner wrote to respondent’s Service Center in Ogden, Utah, acknowledging receipt of the notice of deficiency dated February 4, 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 the Secretary of the Treasury and the 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.4 However, petitioner chose not 3 Insofar as their ultimate tax liability was concerned, respondent gave petitioner and his wife credit for the amounts withheld from petitioner’s wages. However, we note that the determination of a statutory deficiency does not take such withheld amounts into account. See sec. 6211(b)(1). 4 In this regard, petitioner’s letter dated Feb. 23, 2000, stated as follows: (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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