T.C. Memo. 2008-39
UNITED STATES TAX COURT
RODOLFO LIZCANO, Petitioner v.
COMMISSIONER OF INTERNAL REVENUE, Respondent
Docket No. 211-03. Filed February 26, 2008.
R determined a deficiency in income tax for P’s
1999 tax year based primarily on the disallowance of
claimed business expenses. R mailed to P a notice of
deficiency that incorrectly provided the last day P
could petition the Tax Court. P claims that the notice
of deficiency is invalid and alleges that the
examination and audit were illegal and retaliatory.
Held: The notice of deficiency is valid because P
received the notice timely and petitioned the Tax Court
timely.
Held, further, the examination and audit of P’s
1999 Federal income tax return were in accordance with
applicable law.
Held, further, R’s deficiency determination is
sustained.
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Last modified: March 27, 2008