U.S. Auto Sales, Inc. v. Commissioner

153 T.C. No. 5

UNITED STATES TAX COURT U.S. AUTO SALES, INC., Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 20050-12. Filed October 28, 2019. R issued to P an 11-page document purporting to be a notice of deficiency, dated May 15, 2012 (May notice), for P’s taxable years ending (TYE) June 30, 2003 and 2007, wherein R purportedly determined deficiencies of $24,480 and $30,668, respectively. The first four pages of the May notice identify P as the taxpayer, while the last seven pages identify a separate corporation, related to P, as the taxpayer. On Aug. 10, 2012, P…