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addition to tax under section 6651(a)(1) for failure to timely
file his 2000 return.
In October 2003, over 6 months after respondent issued the
statutory notice of deficiency in this case, respondent mailed to
petitioner a letter advising of changes to petitioner's statement
of account for 1999 indicating that for 1999 "the amount you now
owe" is "none".
Discussion
A. Estoppel
As a preliminary matter, petitioner contends that he does
not owe any tax for 1999 because he received a letter from the
IRS dated October 13, 2003, which stated that corrections had
been made to his 1999 tax account and "the amount you now owe" is
"none".
It appears that respondent erroneously assessed the amount
shown on the notice of deficiency for petitioner's 1999 taxable
year. The letter respondent sent petitioner on October 13, 2003,
reversed that assessment because it had been made while
petitioner's case was pending before this Court. See sec.
6213(a).
Petitioner alleges that he is no longer liable for the
deficiency in tax and the section 6651(a)(1) addition to tax for
1999, claiming that respondent's October letter led him to
believe that his case had been resolved:
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