- 4 - last known address and that he did not receive the notices of deficiency. Respondent asserts that petitioner’s underlying tax liability is not before the Court. Respondent contends that there is no evidence petitioner did not receive the notices of deficiency. The parties ask the Court to decide primarily whether petitioner received a notice of deficiency for any of the subject years. If he did, he would be precluded from challenging his underlying tax liability for the related year or years. We need not and do not decide that issue. Assuming arguendo that petitioner did not receive a notice of deficiency for any of the subject years and thus was entitled to challenge his underlying tax liability for each of those years, he has not established that he is entitled to any of the additional deductions which he claims. Petitioner did not provide at trial any evidence, in the form of either testimony or documentation, to support his claim to any additional deduction. In fact, he chose to present no evidence at all other than by way of the stipulated facts and exhibits, none of which adequately supports his claim. Given that petitioner set forth in his petition no allegation that respondent abused his discretion, that petitioner has not claimed that the proposed method of collection is inappropriate, that petitioner has not offered any alternative means of collection,Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011