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Steven Sego and Davina Sego, pro se.
Thomas N. Tomashek, for respondent.
OPINION
COHEN, Judge: The petition in this case was filed in
response to two Notices of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330. Unless otherwise
indicated, all section references are to the Internal Revenue
Code in effect for the years in issue. The notice of
determination sent to Steven Sego set forth the following:
Summary of Determination
The Service should proceed with the proposed levy
action.
Matters Considered at your Appeals hearing
• The requirements of various applicable law or
administrative procedures have been met based upon
the best information available.
• No spousal defenses were raised.
• No offers of collection alternatives were made.
• Challenges to the existence or amount of liability
were raised including additional challenges as to
the appropriateness of the collection actions on
the basis of moral, religious, political,
constitutional, conscientious, or similar grounds.
• On August 13, 1997, the Service issued a notice of
deficiency to you for taxable years ending
December 31, 1993, 1994, and 1995. The notice of
deficiency was mailed to your last known address.
You failed to petition the Tax Court for
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