Legal Opinion

Bongam v. Comm'r

United States Tax Court

Decided February 11, 2016No. Docket No. 20104-14LPublishedCited by 5 opinions

In an effort to collect P's unpaid liabilities, R issued P a Notice of Federal Tax Lien Filing and Your Right to a Hearing (NFTL Notice). The NFTL Notice was sent by certified mail to P at an address in Bowie, Maryland (Maryland address). At all relevant times, the Maryland address was P's last known address. P timely requested a collection due process (CDP) hearing, showing as his address an address in Washington, D.C.

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In an effort to collect P's unpaid liabilities, R issued P a Notice of Federal Tax Lien Filing and Your Right to a Hearing (NFTL Notice). The NFTL Notice was sent by certified mail to P at an address in Bowie, Maryland (Maryland address). At all relevant times, the Maryland address was P's last known address. P timely requested a collection due process (CDP) hearing, showing as his address an address in Washington, D.C. (Washington address). The CDP hearing was held, and R determined that P was not entitled to relief. R then sent P by certified mail a Notice of Determination (Notice) denying…

1Opinion of the Court

ISAIAH BONGAM, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent

Bongam v. Comm'r

Docket No. 20104-14L.

United States Tax Court

146 T.C. 52; 2016 U.S. Tax Ct. LEXIS 4; 146 T.C. No. 4;

February 11, 2016, Filed

An order will be issued denying respondent's motion to dismiss for lack of jurisdiction.

In an effort to collect P's unpaid liabilities, R issued P a Notice of Federal Tax Lien Filing and Your Right to a Hearing (NFTL Notice). The NFTL Notice was sent by certified mail to P at an address in Bowie, Maryland (Maryland address). At all relevant times, the Maryland address was P's last…

2Cases cited27 opinions

  1. Davis v. CommissionerUnited States Tax Court · 2000
  2. Frieling v. CommissionerUnited States Tax Court · 1983
  3. Lunsford v. Comm'rUnited States Tax Court · 2001
  4. Looper v. CommissionerUnited States Tax Court · 1980
  5. Estate of Young v. CommissionerUnited States Tax Court · 1983

22 more not listed; retrieve them via the Exa API.

3Cited by5 opinions

  1. Weiss v. Comm'rUnited States Tax Court · 2016
  2. Whistleblower 26876-15W v. Comm'rUnited States Tax Court · 2016
  3. Belair Woods, LLC, Effingham Managers, LLC, Tax Matters Partner v. CommissionerUnited States Tax Court · 2020
  4. James Anthony Ransom v. CommissionerUnited States Tax Court · 2018
  5. Lincoln C. Pearson & Victoria K. Pearson v. CommissionerUnited States Tax Court · 2017

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