Ulysses Thomas was audited by the IRS in 2022. During the au…
Ulysses Thomas was audited by the IRS in 2022. During the audit, Ulysses filed a formal written protest challenging the IRS’s position and requesting Appeals consideration. Ulysses’ case was heard by Appeals, but Appeals found that the IRS’s determinations were correct and that there were no hazards of litigation to justify settling in favor of the taxpayer. A statutory notice of deficiency was issued, and Ulysses immediately petitioned the Tax Court. Ulysses now wishes to have his case heard by the Independent Office of Appeals. Is Ulysses entitled to Appeals consideration?