- 2 - 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 unpaidPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011