Roger L. Sherer - Page 1

                                 T.C. Memo. 2006-29                                   

                               UNITED STATES TAX COURT                                

                           ROGER L. SHERER, Petitioner v.                             
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No. 15976-04L.           Filed February 21, 2006.               

                    P seeks relief from a tax lien filed for 1999                     
               under sec. 6330(d), I.R.C.  P contests the income tax                  
               liability assessed for 1999.  R disputes whether P had                 
               an opportunity to contest the 1999 liability and                       
               asserts P refused receipt of the notice of deficiency.                 
               However, P did not receive the notice of deficiency for                
               1999 which was mailed to two addresses, neither of                     
               which was P’s residence at the time.                                   
                    P did not file an income tax return for 1999.  In                 
               response to the Appeals officer in the communications                  
               after his request for a hearing under sec. 6330,                       
               I.R.C., P provided support for his claimed bases in                    
               securities, the proceeds of the sale of which create                   
               the 1999 liability.  The Appeals officer declined to                   
               consider P’s information until he filed a return for                   
               1999.  Since P did not file a 1999 return, R issued a                  
               notice of determination.                                               

Page:   1  2  3  4  5  6  7  8  9  Next

Last modified: May 25, 2011