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claimed by respondent. Petitioner responded to the 30-day letter
on September 24, 1999, by a letter in which he stated:
I am requesting an office audit/meeting at which time
you should have available:
1. The “text of any written determination and any
background file documents relating to (the)
determination” that my “zero” return was not
correct as provided in 26 USC 6610.
2. Since Sections 6001 and 6011 (as referred to in
the Privacy Act Notice that is contained in the
1040 booklet) only direct me to comply with
Treasury regulations, I will expect you to have
the Treasury regulation that imposes upon me a
legal obligation to treat seriously the “changes”
you have proposed in my 1998 return.
3. The statute and implementing regulation that
allowed you to “change” my 1998 return, and
4. Your Delegation Order from the Secretary of
Treasury authorizing you to act in his behalf.
On October 22, 1999, respondent mailed to petitioner and his
wife a notice of deficiency for 1998, in which respondent
determined that petitioner and his wife owed a deficiency of
$6,724, a $759 accuracy-related penalty under section 6662(a),
and a $191 addition to tax under section 6654(a) for failure to
pay estimated tax.
Petitioner and his wife did not file a petition with the
Court to redetermine the deficiency. Instead, petitioner mailed
a letter dated October 29, 1999, to the Director of the Internal
Revenue Service Center in Fresno, California, stating that he
would not file a petition with the Court until the director
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