Charles Vernon Roberts - Page 13

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          community income to him.  In addition, petitioner contends that             
          the proof of claim filed by the IRS in the bankruptcy proceeding            
          indicates the 1983 Federal income tax owed was $900, that the IRS           
          has a history and reputation for making mistakes in processing              
          returns, and that respondent did not offer the necessary                    
          foundational information into evidence to support the notice of             
          deficiency.                                                                 
               It is well established that, in the absence of exceptional             
          circumstances, the Court will not look behind a deficiency notice           
          to determine whether the Commissioner's agents followed proper              
          administrative procedures.  Human Engg. Inst. v. Commissioner, 61           
          T.C. 61, 66 (1973); see also Greenberg's Express, Inc. v.                   
          Commissioner, 62 T.C. 324, 327 (1974).  Even in such exceptional            
          circumstances, the Court will generally not hold the deficiency             
          notice null and void to relieve the taxpayer of any tax                     
          liability.  Greenberg's Express, Inc. v. Commissioner, supra at             
          328.                                                                        
               With respect to petitioner's argument that the notice of               
          deficiency is arbitrary and unreasonable because it is erroneous,           
          we disagree.  Petitioner's testimony, standing alone, that he               
          signed the Federal return and gave it to Mr. Henschel to mail               
          does not establish that the Federal return was actually mailed.             
          Moreover, the fact that respondent allocated all of the community           







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