In an appeal from the tax court's decision denying taxpayers' appeal from an IRS collection due process hearing, the order is affirmed where the taxpayers' waiver of their right to receive a notice of deficiency did not require acceptance by the IRS to become effective, and the taxpayers had waived their pre-collection right to contest liability.
Read Ulrich v. Comm'r. of Int'l. Rev., No. 08-70718
Appellate Information
Argued and Submitted September 17, 2009
Filed November 3, 2009
Judges
Per Curiam
Counsel
For Petitioners:
Joe Alfred Izen, Jr., Bellaire, TX
For Respondent:
Nathan J. Hochman and Steven W. Parks, Attorneys, Tax Division, Department
of Justice, Washington, DC
