115 T.C. No. 39
UNITED STATES TAX COURT
TERRY HIRAM PIERSON, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 8650-00L. Filed December 14, 2000.
R issued a notice of deficiency to P for the
taxable year 1988, but P did not file a petition for
redetermination with the Court. R subsequently issued
a notice of intent to levy. 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 a challenge to the
underlying liability would not be considered because P
had received a notice of deficiency. P filed an
imperfect petition with the Court for review of
respondent’s determination to proceed with collection.
However, the petition did not contain any specific
allegations. R moved to dismiss for failure to state a
claim. The Court then directed P to file a proper
amended petition, but P failed to do so. Rather, P
filed a statement asserting that he is not liable for
the underlying liability based on frivolous and
groundless arguments.
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