Salery v. Commissioner of Internal Revenue

Oliver David Salery appeals pro se from the United States Tax Court’s dismissal of his pro se petition challenging the determination of the Commissioner of the Internal Revenue Service (“IRS”) that he was hable for income tax deficiencies and penalties for the 2001 tax year. 1 Salery argues that the Tax Court erred by failing to rule on the merits of his petition, committed fraud, and was biased or prejudiced against him. The IRS responds that the Tax Court properly dismissed Salery’s petition for lack of subject matter jurisdiction because it was untimely as to the notice of deficiency for…