- 4 - By letter dated October 5, 1999, petitioners wrote to the Director of respondent’s Service Center in Ogden, Utah, acknowledging that they received the notice of deficiency for 1996, but challenging the Director’s authority to issue such notices. On October 20, 1999, petitioners wrote a similar letter to the Director with regard to the notice of deficiency for 1997. Petitioners knew that they had the right to contest respondent’s deficiency determinations by filing a petition for redetermination with this Court. However, petitioners chose not to do so. On January 3, 2000, respondent entered assessments against petitioners for the deficiency and accuracy-related penalty determined in the notice of deficiency for 1997 described above. Respondent also entered an assessment against petitioners for statutory interest. On January 3, 2000, respondent issued to petitioners a notice of balance due informing petitioners that they owed tax for 1997 and requesting that they pay that amount. Petitioners failed to pay the amount owing. On February 7, 2000, respondent entered assessments against petitioners for the deficiency and accuracy-related penalty determined in the notice of deficiency for 1996 described above. Respondent also entered an assessment against petitioners for statutory interest. On February 7, 2000, respondent issued to petitioners a notice of balance due informing petitioners thatPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011