- 4 -
filing requirements, or (3) did not receive a
notice of deficiency.
• 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 accept delivery of said notice of
deficiency and you subsequently failed to timely
petition the Tax Court for redetermination of the
proposed liability. The liability as reflected in
the notice of deficiency was based upon the
community property laws of the State of Idaho and
your proportionate share of the community income.
• Appeals believes the proposed enforcement action
balances the need for the efficient collection of
taxes with your concerns as to the intrusiveness
of the action to be taken.
In the petition, it is alleged that, after a conference
conducted with an Internal Revenue Service Appeals officer,
petitioners received additional documents relating to disputed
gains on sales transactions and that petitioners “found that the
IRS had created income to Petitioners based on statistics, and
this was unknown to Petitioners until after the conference”. The
petition also contains various accusations concerning the
credibility of the statements in the above-quoted notices of
determination.
Respondent contends that section 6330(c)(2)(B) precludes
petitioners from challenging the existence or amount of their
income tax liability for 1993, 1994, and 1995, because
petitioners had received statutory notices of deficiency for that
liability.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011