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wages, line 22 for total income, and line 33 for adjusted gross
income. Petitioner also entered a zero on line 56 for total tax
and claimed a refund in the amount of $198.93 reflecting Federal
income tax withholding.
B. Respondent’s Deficiency Notices and Petitioner’s Response
On February 5, 1999, respondent issued a notice of
deficiency to petitioner. In the notice, respondent determined a
deficiency in the amount of $1,924 in petitioner’s Federal income
tax for 1996 and an accuracy-related penalty under section
6662(a) for negligence or disregard of rules or regulations in
the amount of $100. The deficiency was based on respondent’s
determination that petitioner failed to report wage income (as
reported to respondent by third-party payors on Forms W-2, Wage
and Tax Statement).
By letter dated April 3, 1999, petitioner wrote to the
Director of respondent’s Service Center in Ogden, Utah,
acknowledging receipt of the notice of deficiency dated February
5, 1999, but challenging the Director’s authority to issue such
notices.
On March 24, 2000, respondent issued a notice of deficiency
to petitioner. In the notice, respondent determined a deficiency
in the amount of $2,441 in petitioner’s Federal income tax for
1998 and an accuracy-related penalty under section 6662(a) for
negligence or disregard of rules or regulations in the amount of
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