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Background
Petitioner resided in Steger, Illinois, at the time he filed
the petition in this case.
On or about October 13, 1997, petitioner filed a Form 1040,
U.S. Individual Income Tax Return, for 1996, reporting total
income of zero and total tax of zero.
On September 7, 1999, respondent issued a notice of
deficiency to petitioner for 1996 determining an income tax
deficiency of $38,005, an addition to tax under section
6651(a)(1) of $9,501, and an accuracy-related penalty under
section 6662 of $7,601. The deficiency was based on respondent’s
determination that petitioner failed to report nonemployee
compensation of $115,234.
Petitioner did not file a petition with respect to the
notice of deficiency. Instead, on September 13, 1999, petitioner
sent a letter to the Internal Revenue Service which stated, in
part:
Nothing in the Privacy Act Notice or in the above statutes
informs me that I have to “comply” with, or pay attention
to, letters and/or alleged “determinations” sent to me by
various and sundry employees of the IRS.
On April 10, 2000, respondent assessed petitioner’s tax,
addition to tax, penalty, and interest for a total unpaid
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Last modified: May 25, 2011