Michael J. Yacksyzn - Page 5




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          report: (1) Wage income in the amount of $46,659 received by                
          petitioner from Kerr-McGee Corp.; and (2) taxable pension                   
          distributions in the amounts of $17,696, $585, and $171 received            
          by petitioner from Defense Finance and Accounting Service,                  
          Putnam Fiduciary Trust Co., and Kerr-McGee Corp. Savings                    
          Investment Plan, respectively.                                              
               By registered letter dated January 27, 2000, petitioner                
          wrote to respondent, acknowledging receipt of the notice of                 
          deficiency dated November 5, 1999, but challenging respondent’s             
          authority “to send me the Notice in the first place.”                       
               Petitioner knew that he had the right to contest                       
          respondent’s deficiency determination by filing a petition for              
          redetermination with this Court.  However, petitioner chose not             
          to do so.  Accordingly, on May 1, 2000, respondent assessed the             
          determined deficiency and accuracy-related penalty, as well as              
          statutory interest.  On that same day, respondent notified                  
          petitioner that he owed $5,281.87 and requested that he pay such            
          amount.3  Petitioner failed to do so.                                       



               3  The May 1, 2000, notice and demand for payment computed             
          the balance due as follows:                                                 
                    Assessed deficiency    $14,972.20                                 
                    Assessed penalty           748.64                                 
                    Assessed interest          790.03                                 
                    Subtotal                16,510.87                                 
                    Less: withholding      -11,229.00                                 
                    Balance due              5,281.87                                 





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