An IRS appeals officer failed to verify the proper mailing of a notice of deficiency and incorrectly sustained a determination, the U.S. Tax Court ruled May 20.
Jevon Kearse, a retired NFL player, was denied a deduction of $1.36 million for a business bad debt expense on his 2010 federal income tax return. The Internal Revenue Service sent a notice of deficiency in May 2012 with the determination followed by a notice of federal tax lien. Kearse played for the Tennessee Titans and Philadelphia Eagles from 1999-2010.
Kearse argued that he hadn’t ...
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