Patricia Ann Blocker - Page 4

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          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.                                                   
               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                  

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