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Revenue.
Petitioners knew that they had the right to contest
respondent’s deficiency determination by filing a petition for
redetermination with this Court.3 However, petitioners chose not
to do so. Accordingly, on November 20, 2000, respondent assessed
the determined deficiency and accuracy-related penalty, as well
as statutory interest. On that same day, respondent sent
petitioners a notice of balance due, informing them that they had
a liability for 1997 and requesting that they pay it. By letter
dated December 20, 2000, petitioners acknowledged receipt of the
notice of balance due,4 but failed to pay the amount owing.
C. Respondent’s Final Notice and Petitioner’s Response
On March 1, 2001, respondent mailed to petitioners a Final
Notice--Notice of Intent to Levy and Notice of Your Right to a
3 In this regard, petitioners’ letter dated July 11, 2000,
stated as follows:
According to your “Deficiency Notice” of above date
(cover sheet attached), there is an alleged deficiency
with respect to our 1997 income tax of $2,854.00, and
in order to “contest this deficiency before making
payment, we must “file a petition with the United
States Tax Court”.
4 In this regard, petitioners’ letter dated Dec. 20, 2000,
stated as follows:
This is in reply to your letter of 11/20 in which
you notified me that “We have changed your return.”
Elsewhere in their letter, petitioners espoused the view
that because they did not self-assess themselves on their 1997
Form 1040, they cannot have any tax liability for that year.
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