- 4 - If we don’t hear from you within 30 days from the date of this letter, we will send you a Notice of Deficiency * * * . Petitioners did not respond to respondent’s September 5, 2000, letter within the 30-day period prescribed therein. By notice of deficiency dated November 29, 2000, respondent determined a deficiency in tax with respect to petitioners for 1998 in the amount of $3,068. That deficiency was attributable entirely to respondent’s disallowance of the section 151(c) deductions.4 On February 28, 2001, petitioners filed the petition, assigning error to respondent’s determination. Although Mr. Austen, petitioners’ C.P.A., apparently prepared and mailed the petition, the petition does not identify Mr. Austen or anyone else as representing petitioners, nor did Mr. Austen or anyone else subsequently enter an appearance on behalf of petitioners.5 On an unspecified date, Mr. Austen sent a copy of the petition to the examiner assigned to the case at the Ogden Customer Service Center (the Ogden examiner), along with the following handwritten note: “Dear Mr. Parizek: I ran out of time & filed a petition to Tax Court. If we can resolve the problem thru you great – 4 Although respondent also disallowed the child tax credits that petitioners had claimed for two of the children, such disallowance was not reflected in respondent’s computation of petitioners’ corrected tax liability. 5 We note that Mr. Austen is not authorized to practice before this Court.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011