Gyorgy v. Comm’r of Internal Revenue

The Internal Revenue Service determined that Gyorgy (who did not file tax returns 2001-2007) owed approximately $100,000 in unpaid income taxes, penalties, and interest for tax years 2002 and 2003. The IRS mailed notices of his deficiencies in 2006 and 2007, including demands for payment, to the address on his most recently filed tax return. But Gyorgy no longer lived there and did not receive the notices. More than two years later, his debts were still outstanding, so the IRS filed notice of a federal tax lien on his property. Gyorgy challenged the action in a collection due process (CDP) hearing before the IRS Office of Appeals, which sustained the IRS’s filing of the lien notice, findings that the IRS properly mailed Gyorgy’s deficiency notices under I.R.C. 6212(b)(1) before filing the lien and correctly determined his underlying tax liabilities. The tax court and the Seventh Circuit affirmed, noting that Gyorgy presented no arguments and no evidence before the tax court to challenge the IRS’s calculation of the taxes and penalties he owes. View "Gyorgy v. Comm'r of Internal Revenue" on Justia Law