Steven and Davina Sego v. Commissioner of Internal Revenue

Summary

The Tax Court sustained the Commissioner's collection due process determinations allowing levy to proceed against Steven and Davina Sego for taxable years 1993 through 1995. Because both petitioners received statutory notices of deficiency for those years — Steven returning his marked 'dishonored' and Davina refusing delivery — the express terms of section 6330(c)(2)(B) barred them from contesting the existence or amount of the underlying liabilities, leaving the administrative determination reviewable only for abuse of discretion. Finding no challenge to the appropriateness of the intended collection method, no offer of a collection alternative, and no spousal defense raised, the Court held there was no abuse of discretion and entered decision for respondent.