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typical protester explanation of why they were not required to
report income or pay Federal tax.
On March 17, 2000, respondent mailed a notice of deficiency
to petitioners determining a $9,608 income tax deficiency for
1998, based on petitioners’ income (ostensibly wages) reported to
respondent by several third-party sources, including Gambro
Healthcare, Inc.; Kevin Keep; Mohan Dialysis Center; and Screen
Art, Inc. Respondent also determined an addition to tax under
section 6651(a)(2) and a penalty under section 6662(a) for
petitioners’ 1998 tax year. Petitioners acknowledged receipt of
the deficiency notice in a March 30, 2000, letter to respondent
and, among other similar protester statements, indicated that
“Nothing in the Privacy Act 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.”
Petitioners, however, failed to petition this Court with
respect to the notice of deficiency. Respondent assessed the
income tax deficiency, addition to tax, and penalty; provided
petitioners with notice and demand; and because petitioners
failed to pay, on April 26, 2001, issued a Form Letter 1058,
Final Notice--Final Notice of Intent to Levy and Notice of Your
Right to a Hearing. On May 30, 2001, respondent received a Form
12153, Request for a Collection Due Process Hearing, from
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Last modified: May 25, 2011