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otherwise indicated, all section references are to the Internal
Revenue Code in effect for the years in issue, and all Rule
references are to the Tax Court Rules of Practice and Procedure.
Background
All of the facts have been stipulated, and the stipulated
facts are incorporated in our findings by this reference.
Petitioners resided in Carey, Ohio, at the time they filed
their petition.
Petitioners timely filed Forms 1040, U.S. Individual Income
Tax Returns, for 1996, 1997, and 1998, reporting income received
in the amounts of $8,595, $9,593, and $8,618, respectively. On
the Form 1040 for 1998, petitioners inserted above their
signatures a reference to signing the return “under duress”. On
March 30, 2000, respondent sent to petitioners a notice of
deficiency, determining deficiencies of $9,621, $6,313, and
$4,173 for 1996, 1997, and 1998, respectively, and penalties
under section 6662(a) for each of those years.
Petitioners did not file a petition in response to the
notice of deficiency. In their petition in this case, they
acknowledge receipt of the notice of deficiency but claim that it
was not valid because it “was not signed by the Secretary of the
Treasury or his authorized delegate, and the person who signed
the ‘notice of deficiency’ did not have authority to do so
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