- 4 - it can only be a derivative of corporate activity. * * * Respondent’s Notice of Deficiency On February 23, 2000, respondent (acting through Carol M. Landy, Director of the Brookhaven Customer Service Center in Holtsville, New York) issued a notice of deficiency to petitioner for 1997. In the notice of deficiency, respondent determined a deficiency of $12,113 in Federal income tax.2 Respondent determined that petitioner failed to report wages of $60,833, as well as dividends of $20, a gross distribution of $222, interest of $33, and a prior year refund of $341. Petitioner received the notice of deficiency. Petitioner did not file a petition for redetermination with the Tax Court. On September 11, 2000, respondent assessed the determined deficiency, plus statutory interest. On that same date, respondent sent petitioner a notice of balance due. Petitioner failed to pay the amount owing. Respondent’s Notice of Intent To Levy and Petitioner’s Response On January 18, 2001, respondent sent petitioner a notice entitled: “Final Notice--Notice of Intent to Levy and Notice of Your Right to a Hearing.” 2 Respondent determined the deficiency without taking into account the tax withheld from petitioner’s wages, as a statutory notice of deficiency does not take such withheld amount into account. See secs. 31(a), 6211(b)(1). However, insofar as petitioner’s ultimate tax liability is concerned, respondent gives petitioner credit for the amount withheld from his wages.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011