- 3 - 30-day letter proposing a deficiency in their income tax. Respondent mailed the 30-day letter to petitioners at the Lake Forest address. Petitioners received the 30-day letter. On April 17, 2002, petitioners filed with respondent a protest to the 30-day letter indicating their disagreement with the proposed deficiency. In their protest, petitioners listed their address as the Lake Forest address. By notice of deficiency dated August 5, 2002, respondent determined a deficiency in petitioners’ income tax for 2000 in the amount of $4,201. Respondent sent the notice of deficiency to petitioners by certified mail addressed to them at the Lake Forest address.3 The deficiency in income tax was based on respondent’s determination that petitioners failed to report on their 2000 return all of the income received by them during that year. Petitioners did not file a petition for redetermination with this Court in respect of the notice of deficiency. See sec. 6213(a). Accordingly, on December 30, 2002, respondent assessed the deficiency, together with interest as provided by law, and sent petitioners a notice and demand for payment. Petitioners did not pay the amount owing. 3 The notice of deficiency was placed in the mail on Aug. 3, 2002, two days before the typewritten date appearing on the notice. Nevertheless, the notice correctly informed petitioners that the last day to file a petition for redetermination with this Court was Monday, Nov. 4, 2002.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011