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respondent’s determination that collection action could proceed
for Federal income tax liabilities for 1998.
Background
At the time his petition was filed, petitioner resided in
Nice, California.
On March 18, 1999, petitioner and his wife, Laura E.
Rewerts, filed a joint Federal income tax return for 1998 (1998
tax return), reporting a total income of zero. Petitioner and
his wife attached to their 1998 tax return a 2-page letter that
asserted basic tax-protester arguments. They also attached Forms
W-2, Wage and Tax Statement, for 1998 that reported wages
petitioner received from Stergion Construction and Lakeport
Unified School District of $30,032 and $733, respectively, and
wages petitioner’s wife received from Lakeport Unified School
District of $25,425.2 Petitioner and his wife claimed the
Federal income tax shown as withheld on the W-2s, totaling
$2,928, as a refund on the 1998 tax return.
On September 3, 1999, respondent mailed petitioner and his
wife a letter requesting them to respond within 30 days to
proposed adjustments to their 1998 tax return (30-day letter).
The 30-day letter proposed an additional $4,928 in taxes,
additions to tax, penalties, and estimated interest being
2 Amounts are rounded to the nearest dollar.
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