- 3 - and the Internal Revenue Service is not entitled to change his return. On April 4, 2001, respondent mailed petitioner a Letter CP- 2000 stating: “WE’RE PROPOSING CHANGES TO YOUR 1999 TAX RETURN”, in which respondent proposed changes to petitioner’s 1999 return based upon reported income from third-party payors. In response, by letters dated April 9 and May 15, 2001, petitioner disputed respondent’s authority to assess tax and asserted other tax- protester arguments. On June 20, 2001, respondent mailed to petitioner a notice of deficiency for 1999, in which respondent determined that petitioner and his wife owed a deficiency of $7,758, and a $1,552 accuracy-related penalty under section 6662(a). In response, by letter dated July 27, 2001, petitioner acknowledged receipt of the notice of deficiency and again raised tax-protester arguments. Petitioner did not file a petition with the Court to redetermine the deficiency. Respondent assessed the tax, penalty, and interest on October 15, 2001. On January 8, 2003, respondent filed a Notice of Federal Tax Lien (NFTL) with the Recorder of Cuyahoga County, Cleveland, Ohio, with respect to petitioner’s 1999 tax liabilities, and on January 13, 2003, respondent mailed petitioner a Letter 3172(DO) (Rev. 11-2000), Notice of FederalPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011