Steven and Davina Sego - Page 4




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                    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.                                                                  






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