Goza v. Commissioner
United States Tax Court
The Tax Court has held that a tax protester was not entitled to contest his tax liability before the IRS appeals office under section 6330(d) because he had already received a deficiency notice and had disregarded his opportunity to challenge the liability. In 1997 the IRS issued a deficiency notice to Howard Goza for years 1994-96; Goza returned the notice to the IRS with an attached statement indicating that he was not liable for taxes.
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The Tax Court has held that a tax protester was not entitled to contest his tax liability before the IRS appeals office under section 6330(d) because he had already received a deficiency notice and had disregarded his opportunity to challenge the liability. In 1997 the IRS issued a deficiency notice to Howard Goza for years 1994-96; Goza returned the notice to the IRS with an attached statement indicating that he was not liable for taxes. The IRS later issued a notice of intent to levy, which Goza again returned with the same frivolous statement. The IRS then issued a determination letter,…
1Opinion of the Court
OPINION
Cohen, Chief Judge:
This case was assigned to Chief Special Trial Judge Peter J. Panuthos pursuant to the provisions of section 7443A(b)(4) and Rules 180, 181, and 183. Unless otherwise indicated, section references are to sections of the Internal Revenue Code as amended, and Rule references are to the Tax Court Rules of Practice and Procedure. The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Panuthos, Chief Special Trial Judge: This matter is before the Court on respondent’s motion to dismiss for failure…
2Cases cited1 opinion
- Moore v. CommissionerUnited States Tax Court · 2000
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