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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).
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Last modified: May 25, 2011