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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 that
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