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.
Page: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011