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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.
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Last modified: May 25, 2011