- 4 - 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.”Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011