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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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Last modified: May 25, 2011