Petitioner did not respond to the motion despite our ordering him to do so. Nor did petitioner appear for calendar call or the scheduled hearing on the motion. We must therefore decide on a very limited record whether respondent abused his discretion in sustaining the proposed collection action. We hold he did not.
We recite the uncontested facts in the petition, the motion and the exhibits attached to these documents. Petitioner resided in Utah when he filed the petition.
Petitioner failed to file a Federal income tax return for 2007, and respondent prepared a substitute for return for him. Petitioner failed to pay the tax shown on the substitute for return (2007 tax liability), and respondent prepared a deficiency notice for the 2007 tax liability. Respondent sent the deficiency notice to petitioner’s last known (and current) address by certified mail. Petitioner did not file a petition with this Court to challenge the 2007 tax liability.
Judge(s): Diane Kroupa
Jurisdiction: U.S. Tax Court
Related Categories: Communications , Government / Politics , Property , Securities , Taxation
|Circuit Court Judge(s)|
|Petitioner Lawyer(s)||Petitioner Law Firm(s)|
|Leslie Truex||Pro se|
|Respondent Lawyer(s)||Respondent Law Firm(s)|
|Skyler Bradbury||Internal Revenue Service|
|Charles Burnett||Internal Revenue Service|