Steven and Davina Sego - Page 1

                                   114 T.C. No. 37                                    

                               UNITED STATES TAX COURT                                

                       STEVEN AND DAVINA SEGO, Petitioners v.                         
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 12313-99L.            Filed June 30, 2000.                  

                    Ps commenced a proceeding in response to two                      
               Notices of Determination Concerning Collection                         
               Action(s) Under Section 6320 and/or 6330.  P husband                   
               had received a notice of deficiency but returned it to                 
               the IRS with frivolous language written on it; he did                  
               not file a petition in response to the notice of                       
               deficiency.  Attempts to deliver the notice of                         
               deficiency to P wife were made at Ps’ residence, but                   
               the notice was returned unclaimed.  Ps seek in this                    
               action to challenge the underlying merits of                           
               respondent’s determination in the statutory notices of                 
               deficiency rather than challenging the appropriateness                 
               of the intended method of collection, offering an                      
               alternative means of collection, or raising spousal                    
               defenses to collection.  Held, there was no abuse of                   
               discretion by respondent in allowing collection to                     

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