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Statutory Notice of Deficiency issued on April 4, 2000,
are not part of this balance owed. This balance owed
shown on the L-1058 was as of 03/09/2000 and was from
the taxpayers’ voluntarily filed original and amended
returns that had been processed by the Service.
As to petitioners’ contention that the amount due had not
been determined, the Appeals officer said: “The amount due, as
shown on the L-1058 dated 03/09/2000, had been determined from
their voluntarily filed original and amended returns.”
On July 5, 2000, after receiving the notice of deficiency,
petitioners filed a petition in this Court which was filed as
docket No. 7464-00. In their petition, petitioners contended:
The tax assessed by the Internal Revenue Service is
incorrect and overstated. Taxpayer believes that the
records generated by the investigation of the Internal
Revenue Service would reveal that said assessment is
premised upon an overstatement of income in taxpayers
amended returns. Further, taxpayer does not believe
that the civil penalties assessed him under IRC Section
6663(a) are applicable to all of the additional
reported income in the years proposed.
On September 7, 2000, after receiving the notices of
determination, petitioners filed a petition in this Court, which
was filed as docket No. 9452-00L. In their petition, petitioners
contended: “The [taxpayers] have petitioned the [T]ax [C]ourt for
the above listed tax years to determine the correct tax
liability, IRS has examined the years in question. Prior to the
start of collection action, the correct liability should be
determined.”
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