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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.
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).
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Last modified: May 25, 2011