Ulrich v. Commissioner

Judson and Sheryl Ulrich appeal a decision of the United States Tax Court denying their appeal from a Collection Due Process Hearing in which the Internal Revenue Service (IRS) Appeals Office determined that the IRS could proceed with collection of the Ulriehs’ 1999, 2000, and 2001 taxes. We have jurisdiction pursuant to 26 U.S.C. § 7482(a)(1). We affirm.

At the conclusion of an audit of the Ulriehs’ 1999, 2000, and 2001 tax returns, the Ulriehs and the IRS Tax Examiner signed IRS Income Tax Examination Changes Form 4549(the Form), which reflected a revised calculation of the Ulriehs’ tax…