- 4 - January 22, 2004, a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330, sustaining the filing of the notice of Federal tax lien, was sent to petitioner. That notice of determination is the basis of the current action. On or about February 2, 2004, petitioner submitted to the IRS an amended 1989 return. In the amended return, petitioner claimed a business loss on Schedule C, Profit or Loss From Business, and claimed an exemption for a dependent not previously claimed. As a result, petitioner contended that her total tax liability for 1989 was $1,939. Petitioner never presented substantiation of the deductions claimed on the amended return. The claimed dependent filed her own return for 1989 and claimed an exemption for herself. OPINION The record in this case is cluttered with irrelevant arguments and factual assertions by both parties that are not supported by evidence in the record. It is undisputed, however, that petitioner did not receive the statutory notice sent in 1993 with respect to her Federal income tax liability for 1989. Therefore, we examine de novo petitioner’s underlying liability for that year as determined in the undelivered statutory notice. See sec. 6330(c)(2)(B); Sego v. Commissioner, 114 T.C. 604 (2000).Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011