Michael Schaper - Page 4




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          regulations in the amount of $534.20.  The deficiency was based             
          principally on respondent’s determination that petitioner failed            
          to report the wage income as reported to respondent by Viking               
          Freight, Inc., on Form W-2.                                                 
               By registered letter dated May 19, 2000, petitioner wrote to           
          the Director of respondent’s Service Center in Ogden, Utah,                 
          acknowledging receipt of the notice of deficiency dated March 3,            
          2000, but challenging the Director’s authority “to send me the              
          Notice in the first place.”                                                 
               Petitioner knew that he had the right to contest                       
          respondent’s deficiency determination by filing a petition for              
          redetermination with this Court.2  However, petitioner chose not            
          to do so.  Accordingly, on August 7, 2000, respondent assessed              
          the determined deficiency, addition to tax, and accuracy-related            
          penalty, as well as statutory interest.  On that same day,                  
          respondent sent petitioner a notice of balance due, informing               
          petitioner that he had a liability for 1997 and requesting that             
          he pay it.  Petitioner failed to do so.                                     



               2  In this regard, petitioner’s letter dated May 19, 2000,             
          stated in pertinent part:                                                   
                    According to your “Deficiency Notice” of above                    
               date (cover sheet attached), there is an alleged                       
               deficiency with respect to my 1997 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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