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$448.41. The deficiency was based on respondent’s determination
that petitioner failed to report wage income (as reported to
respondent by a third-party payor on Form W-2).
By letter dated May 29, 2000, petitioner wrote to the
Director of respondent’s Service Center in Ogden, Utah,
acknowledging receipt of the notice of deficiency dated March 24,
2000, but challenging the Director’s authority to issue such
notices.
Petitioner knew that he had the right to contest
respondent’s deficiency determinations by filing a petition for
redetermination with this Court.2 However, petitioner chose not
to do so. Accordingly, on August 9, 1999, and August 14, 2000,
respondent assessed the determined deficiencies and accuracy-
related penalties, as well as statutory interest, for the taxable
years 1996 and 1998, respectively. On August 9, 1999, respondent
sent petitioner a notice of balance due, informing petitioner
that he had a liability for 1996 and requesting that he pay it.
Petitioner failed to do so. On August 14, 2000, respondent sent
petitioner a notice of balance due, informing petitioner that he
had a liability for 1998 and requesting that he pay it.
Petitioner failed to do so.
2 Petitioner acknowledged his right to file a petition with
this Court in his letters dated Apr. 3, 1999, and May 29, 2000.
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