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therein had no basis in law. The letter offered petitioner and
Mrs. Schwersensky an opportunity to correct the return within 30
days without penalty.
Petitioner subsequently sent only frivolous, tax protester
correspondence to respondent concerning 2000. Respondent
accordingly issued petitioner and Mrs. Schwersensky a notice of
deficiency with respect to 2000, determining that petitioner and
Mrs. Schwersensky had income in the amount of the wages reported
on their Forms W-2, income from the sale of securities of
$600,552, and other income, resulting in a deficiency of
$429,118, and taking into account amounts withheld, an
underpayment of tax of $284,654, plus a $56,931 penalty
determined under section 6662(a) (collectively, including
interest, the 2000 liability). Petitioner and Mrs. Schwersensky
received the notice of deficiency, as petitioner referred to it
in a subsequent letter to respondent challenging the authority of
the individual who issued it and containing additional frivolous
tax protester arguments. However, no petition was filed with
respect to the deficiency notice.
A certified copy of Form 4340, Certificate of Assessments
and Payments, covering petitioner's 2000 taxable year, records
that respondent assessed the 2000 liability on August 19, 2002,
and sent notices of balance due to petitioner on August 19, 2002,
and December 9, 2002.
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