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Note that the Supreme Court in this decision warns the
public that those who pay attention to what federal
employees say “take the risk” that such employees may not be
acting “within the bounds of (their) authority” and that
such employees may even be “unaware of the limitations of
(their) authority.”
Well, I am not prepared to take that risk.
Petitioner did not petition this Court with respect to the Notice
of Deficiency for his 1996 taxable year. Thereafter, the 1996
tax deficiency and penalty was assessed and on October 12, 1998,
notice and demand for payment of the assessed 1996 income tax
liability was made on petitioner.
On November 20, 1998, respondent mailed a Notice of
Deficiency to petitioner determining, for petitioner’s 1997 tax
year, a $23,004 income tax deficiency and a $684.33 addition to
tax under section 6651(a)(2). Again, petitioner acknowledged
receipt of the notice in a January 31, 1999, letter and raised
various protester arguments, but he did not file a petition with
this Court regarding his 1997 income tax deficiency. Thereafter,
respondent assessed the 1997 tax deficiency and notice and demand
was made on petitioner by means of a June 28, 1999, notice.
On September 6, 2000, respondent issued two Form Letters
1058, Final Notice--Notice of Intent to Levy and Notice of Your
Right to a Hearing, one for 1995 and 1996 and the other for 1997
and 1998.2
2 The 1998 liability was for a sec. 6702 civil penalty. In
(continued...)
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