- 4 - Goza v. Commissioner, 114 T.C. 176, 180 (2000). In addition, section 6330(c)(2)(B) establishes the circumstances under which a person may challenge the existence or amount of her underlying tax liability. Section 6330(c)(2)(B) provides that the person may raise at the hearing challenges to the existence or amount of the underlying tax liability if the person did not receive a statutory notice of deficiency for the tax liability or did not otherwise have an opportunity to dispute the liability. Petitioner submitted at trial an eight-page handwritten document that she testified was a summary of her case. The document, rambling and difficult to follow, repeats some allegations from the petition and raises new matter. The new matter includes allegations that an IRS employee stole her car, that President Bush made lewd comments to her by telephone, and that Archibald Cox stole from her a "Red Samsonite suitcase". The evidence she submitted includes a handwritten document for tax year 1995 listing a $6,900 deduction for a 1983 van that she alleges was stolen from her "By President Clinton". Petitioner has alleged that certain correspondence, including the notice of deficiency for 1992, was sent to her using, in whole or in part, her maiden name. She alleges that her maiden name is "not my name". She has, however, not denied receiving notices of deficiency for 1992 and 2000. The Court concludes that petitioner is precluded from challenging thePage: Previous 1 2 3 4 5 6 7 8 Next
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