Stan D. Kaye - Page 4




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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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