Robert Baxter - Page 3




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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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