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.
Read the full summary
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
STEVEN AND DAVINA SEGO, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent
Sego v. Commissioner
No. 12313-99L
United States Tax Court
114 T.C. 604; 2000 U.S. Tax Ct. LEXIS 43; 114 T.C. No. 37;
June 30, 2000, Filed
Decision will be entered for respondent.
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…
2Cases cited9 opinions
- Goza v. CommissionerUnited States Tax Court · 2000
- Sego 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
4 more not listed; retrieve them via the Exa API.