- 3 -
Respondent then applied the reported $19,752.11 in estimated tax
and withholding credits as follows:
1997 income tax liability $476.00
Credited to unpaid balance on 1988 income tax 8,564.17
Credited to unpaid balance on 1989 income tax 7,417.17
Refunded to petitioner 3,294.77
Thereafter, on November 19, 1999, respondent issued to
petitioner a notice of deficiency for the 1997 year. The notice
reflected a deficiency of $23,909, stemming from $65,245 in
unreported income shown on Forms 1099, and an accuracy-related
penalty under section 6662(a) of $4,782. In response, petitioner
mailed to respondent a letter dated January 28, 2000,
acknowledging his right to file a petition with the Tax Court but
stating, among other things: “Before I file, pay, or do anything
with respect to this ‘Notices’ I must first establish whether or
not it was sent pursuant to law, whether [sic] not is [sic] has
the ‘force and effect or [sic] law,’ and whether (GWEN A. KRAUSS)
Director of the IRS Service Center had any authority to send me
the Notice in the first place.”
Petitioner did not file with the Court a petition contesting
the deficiency notice. On April 17, 2000, respondent assessed
the $23,909 deficiency and the $4,782 penalty, as well as
$4,920.09 of interest, and sent to petitioner a notice of the
2(...continued)
the $476 assessment is not before us. We therefore construe
petitioner’s arguments as pertaining solely to the subsequent
assessment discussed hereafter.
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