Harold F. Behling - Page 1

                                  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               tax lien would not be withdrawn because P had failed to                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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