- 12 - bankruptcy court order and of the trustee’s letter explaining that amounts paid by Nationwide directly to the trustee were erroneously included on a Form 1099-MISC issued to petitioner and (2) the closing letter, which begins “[t]hank you for giving us more information about the income we recently wrote to you about”, indicates that the latter was written in response to the former. Moreover, it is clear that petitioner’s March 13, 1998, fax was prompted by the CP 2000 letter from respondent’s Philadelphia Service Center to petitioner, which proposed to increase petitioner’s 1996 income by amounts reported on 1099- MISCs as paid to petitioner by Nationwide and Ford Motor Credit during that year. A further indication that the closing letter concerns the proposed additional tax (not petitioner’s self- determined, unpaid tax) is provided by the following sentence contained therein: “If you have already received a notice of deficiency, you may disregard it.” A notice of deficiency is issued in connection with an additional amount of tax, not with respect to a self-determined, unpaid tax, which is immediately assessed pursuant to section 6201(a)(1). Lastly, Appeals Officer Sansbury provided unchallenged testimony that a closing letter (CP 2005) is customarily issued in connection with a notice of proposed changes (CP-2000).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011