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leave. When the petition was filed, petitioner resided in
Fairfield, Iowa.1
Background
On December 3, 2004, respondent issued to petitioner a
Notice of Determination Concerning Collection Actions(s) Under
Section 6320 and/or 6330 (notice of determination) regarding her
unpaid Federal income taxes for 1999 and 2000.2 Respondent’s
Office of Appeals determined that it was appropriate to collect
petitioner’s unpaid taxes by levy unless petitioner exercised her
right to judicial review. On December 29, 2004, petitioner sent
to the Court a document, which states in relevant part:
Dear Tax Court Judge,
I received a deficiency letter from the IRS.
I need your assistance regarding a Notice of Deficiency
I received from the Internal Revenue Service. The
letter states that I must file a petition with the U.S.
Tax Court if I believe the IRS numbers are wrong. I
think the IRS is wrong but I am not sure if I am doing
this protest correctly. Can you please respond with
instructions regarding the procedures I am to take?
Will you please assist me and explain what is going on?
When am I supposed to appear in court over this? Will
I receive any assistance from the courts in acquiring
legal representation?
1 The Court subsequently changed petitioner’s address to
Kihei, Hawaii, on the basis of petitioner’s notification in her
motion for leave.
2 Unless otherwise indicated, all section references are to
the Internal Revenue Code in effect for the years in issue, and
all Rule references are to the Tax Court Rules of Practice and
Procedure.
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Last modified: May 25, 2011