Howard Goza - Page 1

                                    114 T.C. No. 12                                      

                                UNITED STATES TAX COURT                                  

                              HOWARD GOZA, Petitioner v.                                 
                     COMMISSIONER OF INTERNAL REVENUE, Respondent                        

               Docket No. 15444-99L.                  Filed March 17, 2000.              

                    R issued a notice of deficiency to P for the                         
               taxable years 1994, 1995, and 1996.  P returned the                       
               notice of deficiency to R marked "I hereby refute and                     
               invalidate this unsigned Presentment without dishonor.                    
               I do not owe this or any amount of money.  All rights                     
               reserved, without prejudice, UCCI-207."  P did not file                   
               a petition for redetermination with the Court.  R                         
               subsequently issued a notice of intent to levy to P                       
               indicating that R intended to collect the taxes due for                   
               the taxable years 1994, 1995, and 1996.  P requested                      
               and received an administrative review of the proposed                     
               collection action.  R issued a notice of determination                    
               to P stating that all applicable laws and                                 
               administrative procedures had been met and that                           
               collection would proceed.  R further advised P that                       
               challenges to the underlying liability would not be                       
               considered since P received a notice of deficiency.  P                    
               filed a timely petition for review with the Court                         
               contesting the notice of determination on the ground                      
               that he is not liable for the underlying tax                              

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