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On March 13, 1998, petitioner faxed to respondent (1) a copy
of a 1994 order of a United States Bankruptcy Court (the
bankruptcy court order), which, in effect, required that payments
due from Nationwide to petitioner be made directly to the trustee
in bankruptcy of petitioner and Mrs. Banis (the trustee) and (2)
a letter dated March 14, 1997, from the trustee to the
Philadelphia Service Center explaining that an earlier proposal
to assess a negligence penalty against petitioner based upon a
Form 1099-MISC was in error because petitioner did not receive
the payment, which, pursuant to the 1994 order, was made directly
to the trustee for disbursement to creditors.
On April 3, 1998, the Philadelphia Service Center sent a
“closing letter” (Form CP 2005) to petitioner pertaining to 1996
(the closing letter), which provides, in pertinent part, as
follows:
CLOSING LETTER
Thank you for giving us more information about the
income we recently wrote to you about. We are pleased
to tell you that, with your help, we were able to clear
up the differences between your records and your
payers’ records. If you sent us a payment based on our
proposed changes, we will refund it to you if you owe
no other taxes or have no other debts the law requires
us to collect.
If you have already received a notice of
deficiency, you may disregard it. You won’t need to
file a petition with the United States Tax Court to
reconsider the tax you owe. If you have already filed
a petition, the Office of the District Counsel will
contact you on the final closing of this case.
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Last modified: May 25, 2011