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* * * * * * *
*Note #1: The word “income” is not defined in the
Internal Revenue Code. * * * But, as stated above, it
can only be a derivative of corporate activity. * * *
B. Respondent’s Deficiency Notice and Petitioners’ Response
On June 16, 2000, respondent (acting through Deborah Decker,
Director of the Service Center in Ogden, Utah) issued a notice of
deficiency to petitioners for the taxable year 1997. In the
notice, respondent determined a deficiency in petitioners’
Federal income tax in the amount of $2,854 and an accuracy-
related penalty under section 6662(a) and (b)(1) for negligence
or disregard of rules or regulations in the amount of $462.24.2
The deficiency in income tax was based on respondent’s
determination that petitioners had failed to report wages,
interest income, capital gain, and unemployment compensation.
By registered letter dated July 11, 2000, petitioners wrote
to the director of respondent’s Service Center in Ogden, Utah,
acknowledging receipt of the notice of deficiency dated June 16,
2000, but challenging respondent’s authority “to send us the
notice in the first place.” Petitioners sent copies of their
letter by registered mail to Lawrence H. Summers, Secretary of
the Treasury, and Charles O. Rossotti, Commissioner of Internal
2 Insofar as their ultimate tax liability was concerned,
respondent gave petitioners credit for the amounts withheld from
their wages. However, we note that the determination of a
statutory deficiency does not take such withheld amounts into
account. See sec. 6211(b)(1).
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