Don Weber II v. Commissioner

122 T.C. No. 12

UNITED STATES TAX COURT DON WEBER II, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 15169-03L. Filed March 22, 2004. On Dec. 19, 2002, R mailed to P two notices of determination concerning collection action. R issued the first notice with respect to P’s liability for unpaid income taxes; R issued the second notice with respect to P’s liability for an unpaid civil penalty under sec. 6682, I.R.C. R sent both notices to P by certified mail addressed to him at his last known address. The first notice was returned to R by the U.S. Postal Service marked…