Hoyle v. Comm'r
United States Tax Court
R sent P a notice of Federal tax lien, and P filed a request for an Appeals hearing pursuant to sec. 6320, I.R.C. Subsequently, R sent P a notice of determination upholding the Federal tax lien, and P petitioned this Court for review of R's determination. P asserts that R failed to mail to P a notice of deficiency before assessing P's 1993 tax liability.
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R sent P a notice of Federal tax lien, and P filed a request for an Appeals hearing pursuant to sec. 6320, I.R.C. Subsequently, R sent P a notice of determination upholding the Federal tax lien, and P petitioned this Court for review of R's determination. P asserts that R failed to mail to P a notice of deficiency before assessing P's 1993 tax liability. R contends that P may not raise the issue of whether R mailed P a notice of deficiency because P did not raise the issue at the Appeals hearing. Held: This Court will review whether R's Appeals officer verified compliance with applicable law…
1Opinion of the Court
OPINION
WELLS, Judge:
Respondent sent a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination) to petitioner with respect to a lien filed to collect petitioner’s unpaid tax liability for 1993. In response, petitioner timely filed a petition pursuant to section 6330(d),1 seeking review of respondent’s determination. The issues to be decided are: (1) Whether petitioner may raise the issue of whether a notice of deficiency for petitioner’s 1993 taxable year was mailed to petitioner; (2) if petitioner may raise that issue, whether…
2Cases cited11 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- Sego v. CommissionerUnited States Tax Court · 2000
- Giamelli v. Comm'rUnited States Tax Court · 2007
- United States v. Edward M. ZollaCourt of Appeals for the Ninth Circuit · 1984
- Frieling v. CommissionerUnited States Tax Court · 1983
6 more not listed; retrieve them via the Exa API.
3Cited by132 opinions
- Thompson v. CommissionerUnited States Tax Court · 2013
- Hoyle v. CommissionerUnited States Tax Court · 2011
- Mason v. Comm'rUnited States Tax Court · 2009
- Bush v. United StatesCourt of Appeals for the Federal Circuit · 2011
- Jordan v. Comm'rUnited States Tax Court · 2010
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