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all Rule references are to the Tax Court Rules of Practice and
Procedure.
Background
In 1996 and other years, petitioner’s construction company
performed work for the United States Merchant Marine Academy
(USMMA). During 1996, petitioner became concerned about
perceived violations of Federal law on the part of personnel or
contractors working for or associated with the USMMA.
In mid-1996, petitioner contacted respondent about
petitioner’s concerns relating to the above alleged violations of
Federal law.
On June 2, 1997, petitioner timely filed her 1996 individual
Federal income tax return without including payment of the $741
Federal income tax reported due thereon. Respondent assessed the
tax, and respondent sent notice and demand for payment thereof to
petitioner, but the tax remained unpaid through early 2003.
In the summer of 2003, respondent initiated against
petitioner collection activity, levied upon $50 of petitioner’s
State income tax refund, and applied the $50 against petitioner’s
outstanding 1996 Federal income tax.
In response to respondent’s efforts to collect petitioner’s
$741 Federal income tax, petitioner mailed to respondent a letter
in which petitioner represented that she would pay the balance
due, but in which petitioner also referred to violations of
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Last modified: November 10, 2007