Legal Opinion

Sego v. Commissioner

United States Tax Court

Decided June 30, 2000No. 12313-99LPublished

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.

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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

  1. Goza v. CommissionerUnited States Tax Court · 2000
  2. Sego v. CommissionerUnited States Tax Court · 2000
  3. United States v. Edward M. ZollaCourt of Appeals for the Ninth Circuit · 1984
  4. United States v. Edward J. AhrensCourt of Appeals for the Eighth Circuit · 1976
  5. Pietanza v. CommissionerUnited States Tax Court · 1989

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