Louis S. and Laura L. Schnitzler - Page 4




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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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