- 3 -3 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 fromPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011