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T.C. Memo. 2005135UNITED STATES TAX COURTRAYMOND AND CYNTHIA TURNERSIMMONS, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, RespondentDocket No. 315103L. Filed June 9, 2005. Raymond and Cynthia Turner

(Doc. #5-1356). In its determination, the Appeals Office took into consideration the following issues: (1) Respondent's failure to certify to the Deputy Commissioner that it, the Respondent, is in fact an “authorized taxpayer;” (2) inability of respondents to establish a “deferral” by filing timely notice and filing a Form 2323; (3) reliance of respondents on their claim that the failure of the tax collector to serve the Respondent in an annual letter to the Respondent's U.S. address was not subject to a waiver of the waiver provision applicable to notices not served by the United States to persons exempt from U.S. taxation; (4) the failure of respondents to establish a waiver of the waiver provision for certain communications sent by the United States to the respondent's employees; and (5) the inability of the Respondent to establish that the failure of the tax collector to serve the Respondent was “not subject to waiver” because the tax collector had no authority under section 853 of Title 26 of the United States Code to demand a return of all tax payments to the Respondent from its employees. The Court therefore determines that all the issues discussed above have significance, and, therefore, that they should be resolved and analyzed as part of the case. The Court will now provide the details of the record on each of the six issues raised by the Respondent and consecutively addressed to the parties, and the parties shall make a supplemental document in response to the record on each issue raised by the Respondent and consecutively addressed to the parties. 1. Certification by Commissioner under section 1353(a)(2) of the 1986 Code is proper where the Commissioner. certifies, pursuant to section 1352(a)(1) of the 1986 Code (i.e., “in accordance with the applicable Statute”), that the respondent is an “authorized taxpayer.” In this case, in order to satisfy the. certification requirement, it is only necessary that the Respondent file in its office in the United States the Form 2323 or the United States Treasury Form 2555 or a form for a new payment under section 5512 of the 1986 Code.

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