Christopher Gyorgy v. CIR

KANNE, Circuit Judge.

The Internal Revenue Service (“IRS”) determined that Appellant Christopher Gyorgy owed approximately $100,000 in unpaid income taxes, penalties, and interest for tax years 2002 and 2003. The IRS mailed notices of his deficiencies in 2006 and 2007, including demands for payment, to the address on his most recently filed tax return. But Gyorgy no longer lived there and did not receive the notices. More than two years later, his debts were still outstanding, so the IRS filed notice of a federal tax lien on his property in an effort to collect'what he owed. Gyorgy challenged…