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from the adjustments and notified petitioner of the changes to
his tax return on February 5, 2001.
Several months later, respondent determined a $9,823
deficiency for petitioner’s taxable year 1999. The deficiency
was attributable solely to alternative minimum tax (AMT).2
Respondent issued petitioner a notice of deficiency on December
18, 2001, which states in part: “If you want to contest this
determination in court before making payment, you have until * *
* 90 days from the date of this letter * * * to file a petition
with the United States Tax Court.” The notice of deficiency
explains how to obtain a petition and provides the Tax Court’s
mailing address.
On March 18, 2002, petitioner sent a letter to the Internal
Revenue Service in Philadelphia, Pennsylvania, along with a copy
of the notice of deficiency. The letter states: “I do not agree
with the action taken against me reflected in the accompanying
letter. Hence, I would like to petition the U.S. Tax Court. I
want to contest this claim.” Petitioner did not send a copy of
the letter to the Tax Court. Respondent sent petitioner a letter
dated March 26, 2002, informing petitioner that if he wished to
challenge respondent’s determination, he must follow the
instructions contained in the notice of deficiency. Petitioner
2 Petitioner’s 1999 tax return did not include a computation
of his AMT liability.
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