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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.
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Last modified: May 25, 2011