Michael E. Nestor - Page 1

                                   118 T.C. No. 10                                    

                               UNITED STATES TAX COURT                                

                          MICHAEL E. NESTOR, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 5372-00L.              Filed February 19, 2002.             

                    This opinion addresses petitioner’s (P) 1992                      
               through 1997 (1992-97) tax years.                                      
                    Respondent (R) issued notices of deficiency to                    
               petitioner (P) for tax years 1990 through 1997 (1990-                  
               97).  P received the notices of deficiency for tax                     
               years 1992-97 but did not file a petition for                          
               redetermination with the Court.  R issued to P a notice                
               of intent to levy with respect to P’s taxes due for tax                
               years 1990-97.  P requested and R held a hearing                       
               pursuant to sec. 6330(b), I.R.C., relating to P’s tax                  
               years 1990-97.  In his request for a hearing, P                        
               requested that R provide him copies of the assessment                  
               records.  At the hearing, R did not permit P to                        
               challenge his underlying tax liability for tax years                   
               1990-97.  After the hearing, R sent a notice of                        
               determination to P stating that collection of his tax                  
               liability for 1990-97 would proceed.  R provided                       
               assessment records to P after the hearing and before                   
               the trial in this case.                                                

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