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Florida, to foreclose a mortgage. Petitioners filed an answer
and counterclaim to Countrywide’s complaint.
OPINION
The issue for decision is whether respondent correctly
determined to proceed with collection of petitioners’ tax for
1996-2001.
A. Petitioners’ Contentions
Petitioners contend that respondent’s determinations to
proceed with collection should be overturned on the grounds that:
(1) They never received valid notices of deficiency; (2) no
section of the Internal Revenue Code makes them liable for
Federal income taxes; (3) respondent failed to give them a notice
and demand for payment of the taxes in question; (4) respondent
failed to give them verification that all applicable laws and
administrative procedures were followed in this matter; and (5)
collection of the taxes in question would impose an undue
hardship on them.
B. Discussion
1. Whether Petitioners Received Valid Notices of
Deficiency
Although petitioners stipulated that they received notices
of deficiency for 1996-2001, they contend that the notices were
invalid. Petitioners contend that they were improperly precluded
from challenging their underlying tax liability for tax years
1996-2001. They base this contention on their claim that the
notices of deficiency they received were not valid because the
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