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fact that section 6330 now provides an opportunity to contest tax
liability for taxpayers who did not receive a notice of
deficiency, sec. 6330(c)(2)(B), provides no consolation to
petitioners who themselves made the choice not to receive such
notice, see Sego v. Commissioner, 114 T.C. 604, 611 (2000)
(taxpayers who deliberately refused to accept delivery of the
notices of deficiency repudiated the opportunity to contest the
notices of deficiency in the Tax Court).
Second, by failing to file a response to respondent’s motion
and to attend the calendar call, or have someone appear on their
behalf, petitioners waived their right to contest the motion.
Rule 121(d); Lunsford v. Commissioner, 117 T.C. (2001).
Accordingly, we will grant respondent's motion for summary
judgment.
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011