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.
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