Robert L. Perkins v. Commissioner

129 T.C. No. 7

UNITED STATES TAX COURT ROBERT L. PERKINS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 21997-04L. Filed September 13, 2007. P timely filed his Federal income tax return for 2000 but failed to pay fully the amount reported as due. R increased the Federal income tax liability reported by P on his 2000 return and assessed the increase pursuant to sec. 6213(b)(1), I.R.C. After expiration of the period in which to request abatement of the increased assessment under sec. 6213(b)(2), I.R.C., P appealed the increase in a letter that was forwarded to R's Office…