Richard Rewerts - Page 3

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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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