Tax Court Says It Has No Jurisdiction Over Ambiguous Notice

Law360 (October 28, 2019, 6:08 PM EDT) -- A Georgia-based automotive company cannot challenge an Internal Revenue Service notice after the agency erroneously named two businesses in its attempt to levy over $7.6 million in taxes and penalties, the U.S. Tax Court said Monday.

The corporation, U.S. Auto Sales, didn't prove it was the party the IRS issued a notice of deficiency for, Judge L. Paige Marvel said in granting the IRS dismissal of the case for lack of jurisdiction.

"Petitioner provides no evidence beyond the inferential theories noted above. Respondent, in contrast, has introduced documentary evidence that the May notice did not reflect a determination as to petitioner,"...

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