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reported to respondent on Forms W-2, Wage and Tax Statement), (2)
dividend income of $32, and (3) interest income of $36.
By letter dated January 2, 2000, petitioners wrote to the
Director of respondent’s Service Center in Ogden, Utah,
acknowledging receipt of the notice of deficiency dated October
8, 1999, but challenging the Director’s authority to send such a
notice. Petitioners sent a similar letter to Charles O.
Rossotti, Commissioner of Internal Revenue.
Petitioners knew that they had the right to contest
respondent’s deficiency determination by filing a petition for
redetermination with this Court.2 However, petitioners chose not
to do so. Accordingly, on March 27, 2000, respondent assessed
the determined deficiency and accuracy-related penalty, as well
as statutory interest.
On March 27, 2000, respondent sent petitioners a notice
stating that changes were made to their account, informing
petitioners that they had a tax liability for 1997, and
requesting that they pay it. Petitioners failed to do so. On
May 1, 2000, and September 4, 2000, respondent sent petitioners
2 In this regard, the first sentence of petitioners’ letter
dated Jan. 2, 2000, stated as follows:
According to your “Deficiency Notice” of above date
(cover sheet attached), there is an alleged deficiency
with respect to my 1997 income tax of $1,615.82, [sic]
and if I wanted to “contest this deficiency before
making payment,” I must “file a petition with the
United States Tax Court.”
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