Rainer B. and Sonja D. Wagner - Page 5

                                        - 5 -                                         
          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.”                                              

Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  Next

Last modified: May 25, 2011