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to file a return or to pay income taxes. Respondent issued to
petitioners notices of deficiency for 1999 and 2000 on May 18,
2001, and April 12, 2002, respectively. Petitioners responded to
each notice with a letter acknowledging their receipt of the
notice and their right to file a petition with the Tax Court but
stating, inter alia: “Before I file, pay, or do anything with
respect to your ‘Notice,’ I must first establish whether or not
it was sent pursuant to law, whether or not it has the ‘force and
effect of law,’ and whether you had any authority to send me the
notice”.
Petitioners at no time petitioned this Court for
redetermination of the deficiencies and penalties reflected in
the notices. Respondent assessed the tax, penalty, and interest
amounts due for 1999 on November 26, 2001, and sent a notices of
balance due on that date and on December 31, 2001. Likewise,
tax, penalty, and interest for 2000 were assessed on October 21,
2002, and a notice of balance due was sent on that date.
Respondent issued to petitioners a Final Notice of Intent to
Levy and Notice of Your Right to a Hearing dated December 17,
2002, with regard to the 1997, 1998, and 1999 years, and a Notice
of Federal Tax Lien Filing and Your Right to a Hearing Under IRC
6320 dated December 24, 2002, with regard to the 1997 through
2000 taxable years. The latter notice reflected a total amount
due for the 4 years in issue of $20,266.07.
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