Debra L. Chase - Page 8




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          hearing only if the person did not receive a notice of deficiency           
          for the taxes in question or did not otherwise have an earlier              
          opportunity to dispute the tax liability.  See Sego v.                      
          Commissioner, 114 T.C. 604, 609 (2000); Goza v. Commissioner,               
          supra.  Section 6330(d) provides for judicial review of the                 
          administrative determination in either the Tax Court or Federal             
          District Court.                                                             
               Petitioner challenges the existence of the asserted tax                
          liabilities for 1995 and 1996 on the grounds that she did not               
          receive income from a taxable source and respondent failed to               
          demonstrate that she is liable for Federal income taxes.                    
          Although respondent determined that the income in question is               
          attributable to taxable wages, petitioner never identified the              
          alleged nontaxable source of the income, nor did she expressly              
          deny receiving the wages in question.  The record shows that                
          Appeals Officer Johnson gave petitioner every opportunity to                
          produce documentation in support of her position.                           
               Petitioner’s arguments that she is not subject to Federal              
          income taxes and that she did not earn taxable income during 1995           
          and 1996 are frivolous and groundless.  Goza v. Commissioner,               
          supra.  As the Court of Appeals for the Fifth Circuit has                   
          remarked:  “We perceive no need to refute these arguments with              
          somber reasoning and copious citation of precedent; to do so                








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