Harvey Doyne Perry, Jr. - Page 6

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          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                                  

               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:                                                          

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