- 5 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011