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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