Tax Court Holds Mr. Onyango Cannot Dispute 2006 Tax Liability
Mr. Onyango argued that he could challenge his 2006 tax liability under the tax code section allowing a taxpayer to challenge underlying tax liability “if the person did not receive a notice of deficiency for that tax liability or did not otherwise have the opportunity to dispute that tax liability.”
The court, however, disagreed. It stated that “petitioner may not decline to retrieve his Postal Service mail, when he was reasonably able and had multiple opportunities to do so, and thereafter successfully contend that he did not receive for purposes” of contesting tax liability. The court rejected Mr. Onyango request to dispute his tax liability for his taxable year 2006.
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