John C. Bedrosian & Judith D. Bedrosian v. Commissioner

Our society has a longstanding and “‘deep-rooted historic tradition that everyone should have his own day in court.’” Richards v. Jefferson Cnty., Ala., 517 U.S. 793, 798 (1996) (quoting 18 Charles Alan Wright et al., Federal Practice and Procedure, sec. 4449, p. 417 (1981)). “The opportunity to be heard is an essential requisite of due process of law in judicial proceedings.” Id. at 797 n.4. This Court “has consistently and zealously guarded a taxpayer’s right to his day in court, whenever there was a bona fide dispute between him and the Commissioner of Internal Revenue.” Petersen v.…