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.
Argued and Submitted September 17, 2009
Filed November 3, 2009
Joe Alfred Izen, Jr., Bellaire, TX
Nathan J. Hochman and Steven W. Parks, Attorneys, Tax Division, Department
of Justice, Washington, DC