T.C. Memo. 2007-181
UNITED STATES TAX COURT
JACK A. UPCHURCH, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 19730-04L. Filed July 9, 2007.
R mailed a statutory notice of deficiency to P,
which, although it asserted a deficiency and contained
figures and adjustments to P’s gift tax liability for
1996, referenced only 1995. P did not petition this
Court for redetermination. Only in his request for a
hearing after R had issued a notice of intent to levy
and notice of Federal tax lien filing did P raise the
question of the validity of the notice of deficiency.
After the hearing, R’s Appeals officer held the notice
of deficiency to be valid, and, since P raised no other
issue regarding the propriety of the proposed
collection actions, made the determination that the
collection action should proceed.
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Last modified: November 10, 2007