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time off from work to pick up a rhetorical letter from
the IRS.
As petitioner had the prior opportunity to dispute
the liability, and as he raises no other issue in his
petition, the Court should grant the Government’s
motion to dismiss for failure to state a claim upon
which relief can be granted.
The Court: Thank you, Mr. Chinnapongse. Mr. Baxter.
What did you want to say?
Mr. Baxter: I didn’t realize the importance of the
letter they were sending me at the time,
and I did not take time off of work to pick
up.
The Court: How would you know whether it was important
or not unless you looked at it?
Mr. Baxter: I’ve received many certified letters from
the IRS, all stating the same thing, that I
owe money with nothing else included. I
didn’t realize this certain letter was that
important.
The Court: You knew that it was down at that mailbox
waiting for you?
Mr. Baxter: Yes, I did. But I put in a lot of hours at
that job when that came out and I could not
take time off from work.
In Sego v. Commissioner, 114 T.C. 604 (2000), Steven Sego
and Davina Sego petitioned the Court in response to two Notices
of Determination Concerning Collection Action(s) Under Section
6320 and/or 6330, regarding the years 1993, 1994, and 1995. In
their petition, taxpayers sought to challenge their underlying
Federal income tax liabilities for 1993, 1994, and 1995. The
Commissioner alleged that taxpayers were precluded from
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Last modified: May 25, 2011