118 T.C. No. 36
UNITED STATES TAX COURT
HAROLD F. BEHLING, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 4242-01L. Filed June 17, 2002.
R disallowed a loss claimed by P on his Federal
income tax return and issued a notice of deficiency. P
received the deficiency notice and corresponded with R
regarding the loss. R advised P that R would not
change R’s determination. R also advised P of the
deadline for filing a petition for redetermination with
this Court. P, however, did not file a petition, and R
assessed the deficiency.
Subsequently, R filed a notice of Federal tax lien
and provided P with notice of such filing. P filed a
request for an administrative hearing. During the
course of the hearing, R’s Appeals officer considered
the merits of the loss. In the notice of
determination, R informed P that the notice of Federal
tax lien would not be withdrawn because P had failed to
demonstrate that he was entitled to the loss.
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