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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
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...)
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