Pierson v. Commissioner
United States Tax Court
R issued a notice of deficiency to P for the taxable year 1988, but P did not file a petition for redetermination with the Court. R subsequently issued a notice of intent to levy. P requested and received an administrative review of the proposed collection action.
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R issued a notice of deficiency to P for the taxable year 1988, but P did not file a petition for redetermination with the Court. R subsequently issued a notice of intent to levy. P requested and received an administrative review of the proposed collection action. R issued a notice of determination to P stating that all applicable laws and administrative procedures had been met and that collection would proceed; R further advised P that a challenge to the underlying liability would not be considered because P had received a notice of deficiency. P filed an imperfect petition with the Court…
1Opinion of the Court
OPINION
Wells, Chief Judge:
This case was assigned to Special Trial Judge Robert N. Armen, Jr., pursuant to the provisions of section 7443A(b)(5) and Rules 180, 181, and 183.1 The Court agrees with and adopts the opinion of the Special Trial Judge, which is set forth below.
OPINION OF THE SPECIAL TRIAL JUDGE
Armen, Special Trial Judge:
This matter is before the Court on respondent’s motion to dismiss for failure to state a claim upon which relief can be granted. As discussed in detail below, we shall grant respondent’s motion.
Background
On October 6, 1995, respondent issued a notice of deficiency…
2Cases cited4 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- Wilkinson v. CommissionerUnited States Tax Court · 1979
- Hatfield v. CommissionerUnited States Tax Court · 1977
- White v. CommissionerUnited States Tax Court · 1979
3Cited by108 opinions
- Craig v. Comm'rUnited States Tax Court · 2002
- Roberts v. Comm'rUnited States Tax Court · 2002
- Swanson v. Comm'rUnited States Tax Court · 2003
- Keene v. Comm'rUnited States Tax Court · 2003
- Burke v. Comm'rUnited States Tax Court · 2005
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