114 T.C. No. 37
UNITED STATES TAX COURT
STEVEN AND DAVINA SEGO, Petitioners v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 12313-99L. Filed June 30, 2000.
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 appropriateness
of the intended method of collection, offering an
alternative means of collection, or raising spousal
defenses to collection. Held, there was no abuse of
discretion by respondent in allowing collection to
proceed.
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