Gyorgy v. Commissioner of Internal Revenue

U.S. Tax Court did not err in rejecting taxpayer’s challenge to lien notice on his property after IRS had sent tax deficiency notices to address listed on his most recent tax return. While taxpayer testified that he had not actually received any of said deficiency notices, said notices were validly sent because taxpayer had not notified IRS of new address, and new address obtained from any third-party did not count as “clear and concise notification” so as to override address listed on most recent tax return. Fact that IRS had received postal notification that deficiency notice was undeliverable at address listed in most recent tax return did not require different result. Moreover, taxpayer waived any challenge to amount of tax deficiency where he presented no arguments or evidence before Tax Court to challenge IRS’s calculation of taxes.