- 3 - 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 directorPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011