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On December 4, 1998, respondent mailed to petitioner at his
Gray Lane address two separate notices of deficiency related to
petitioner’s 1996 and 1997 taxable years, respectively. In one
notice of deficiency, respondent determined an income tax
deficiency of $3,775 and an accuracy-related penalty under
section 6662(a) of $465 with respect to petitioner’s 1996 taxable
year. In the other notice of deficiency, respondent determined
an income tax deficiency of $4,069 and an accuracy-related
penalty under section 6662(a) of $813.80 with respect to
petitioner’s 1997 taxable year. Each notice of deficiency stated
that the deficiencies could be contested by petitioner’s filing a
petition with the Tax Court 90 days from the date of the notices
of deficiency.
On or about January 12, 1999, petitioner sent two virtually
identical letters to respondent, one for each taxable year at
issue, which contested the authority of the notices of
deficiency. Petitioner did not file a petition with the Tax
Court with respect to the notices of deficiencies.
On May 24, 1999, respondent assessed the income tax
deficiencies and accuracy-related penalties against petitioner
with respect to his 1996 and 1997 taxable years.
On June 14, 1999, respondent assessed a section 6702
frivolous return penalty with respect to each of petitioner’s
taxable years at issue.
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