Sego v. Commissioner
United States Tax Court
Ps commenced a proceeding in response to two Notices of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. P husband had received a notice of deficiency but returned it to the IRS with frivolous language written on it; he did not file a petition in response to the notice of deficiency. Attempts to deliver the notice of deficiency to P wife were made at Ps' residence, but the notice was returned unclaimed.
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Ps commenced a proceeding in response to two Notices of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. P husband had received a notice of deficiency but returned it to the IRS with frivolous language written on it; he did not file a petition in response to the notice of deficiency. Attempts to deliver the notice of deficiency to P wife were made at Ps' residence, but the notice was returned unclaimed. Ps seek in this action to challenge the underlying merits of respondent's determination in the statutory notices of deficiency rather than challenging the…
1Opinion of the Court
OPINION
Cohen, Judge:
The petition in this case was filed in response to two Notices of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330. Unless otherwise indicated, all section references are to the Internal Revenue Code in effect for the years in issue. The notice of determination sent to Steven Sego set forth the following:
Summary of Determination
The Service should proceed with the proposed levy action.
Matters Considered at your Appeals hearing
The requirements of various applicable law or administrative procedures have been met based upon the best information…
2Cases cited8 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- United States v. Edward M. ZollaCourt of Appeals for the Ninth Circuit · 1984
- United States v. Edward J. AhrensCourt of Appeals for the Eighth Circuit · 1976
- Pietanza v. CommissionerUnited States Tax Court · 1989
- Patmon and Young Professional Corporation v. Commissioner of Internal RevenueCourt of Appeals for the Sixth Circuit · 1995
3 more not listed; retrieve them via the Exa API.
3Cited by761 opinions
- Giamelli v. Comm'rUnited States Tax Court · 2007
- Katz v. CommissionerUnited States Tax Court · 2000
- Craig v. Comm'rUnited States Tax Court · 2002
- Montgomery v. Comm'rUnited States Tax Court · 2004
- Magana v. Comm'rUnited States Tax Court · 2002
756 more not listed; retrieve them via the Exa API.