James L. Jensen - Page 12

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          1995.  The notice of deficiency for 1996 and 1997 was sent via              
          certified mail to petitioner’s last known address--which also is            
          the address petitioner used in the petition and the amended                 
          petition.  This notice of deficiency was not returned as                    
          undeliverable.  Respondent submitted a certified mailing list to            
          confirm these facts.  Furthermore, petitioner did not claim that            
          he did not receive the notice of deficiency for 1996 and 1997.              
          Accordingly, petitioner is deemed to have received this notice of           
          deficiency.  Sego v. Commissioner, supra at 610-611.                        
               Petitioner chose not to file a petition for redetermination            
          in response to these notices of deficiency.  Accordingly,                   
          petitioner cannot contest the underlying deficiencies for 1994,             
          1995, 1996, and 1997.  Sec. 6330(c)(2)(B); Sego v. Commissioner,            
          supra; Goza v. Commissioner, supra at 182-183.  Claims that the             
          limitation period for assessment has expired are challenges to              
          the underlying tax liability.  Boyd v. Commissioner, 117 T.C.               
          127, 130 (2001).  Therefore, petitioner cannot raise these claims           
          in this proceeding.                                                         
               Where the validity of the underlying tax liability is not              
          properly in issue, we review the Commissioner’s determination for           
          an abuse of discretion.  Sego v. Commissioner, supra at 610.                
               Petitioner’s remaining argument appears to be that the                 
          verification requirement of section 6330 has not been met.                  
          Section 6330(c)(1) does not require the Commissioner to rely on a           






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