Jack A. Upchurch - Page 1

                                 T.C. Memo. 2007-181                                  

                               UNITED STATES TAX COURT                                

                           JACK A. UPCHURCH, Petitioner v.                            
                    COMMISSIONER OF INTERNAL REVENUE, Respondent                      

               Docket No.  19730-04L.   Filed July 9, 2007.                           

                    R mailed a statutory notice of deficiency to P,                   
               which, although it asserted a deficiency and contained                 
               figures and adjustments to P’s gift tax liability for                  
               1996, referenced only 1995.  P did not petition this                   
               Court for redetermination.  Only in his request for a                  
               hearing after R had issued a notice of intent to levy                  
               and notice of Federal tax lien filing did P raise the                  
               question of the validity of the notice of deficiency.                  
               After the hearing, R’s Appeals officer held the notice                 
               of deficiency to be valid, and, since P raised no other                
               issue regarding the propriety of the proposed                          
               collection actions, made the determination that the                    
               collection action should proceed.                                      

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Last modified: November 10, 2007