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Taxpayer Cannot Challenge His Tax Liability in the Tax Court


Posted on December 04, 2014

Because the taxpayer had unpaid liability due to the IRS, the IRS issued the Final Notice of Intent To Levy seeking to collect the taxpayer’s unpaid liability for 2008 and 2009.

In response, the taxpayer filed a Form 12153, Request for a Collection Due Process or Equivalent Hearing, contending that he was not liable for the unpaid tax liability.

At the hearing, the taxpayer made tax protestor-type arguments stating that the wages he received were not income under the Internal Revenue Code. The IRS previously issued Notices of Deficiency (CP 3219) for both 2008 and 2009.

The taxpayer did not file a Petition in the Tax Court in response to the Notices of Deficiency. However, the taxpayer filed a Petition in the Tax Court following his Collection Due Process hearing with the IRS.

The United States Tax Court held for the IRS, stating that the taxpayer did not timely file a Petition in response to the prior Notices of Deficiency for 2008 and 2009. As such, the taxpayer is now not able to contest the underlying liability in the United States Tax Court.

Have you received a Notice of Deficiency or an Intent to Levy (CP297) from the IRS?
A Petition must be filed in the United States Tax Court within 90 days of the date listed on the Notice of Deficiency.

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