Fay B. Edwards - Page 8

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          taxpayer that any collection action be no more intrusive than               
          necessary.  Sec. 6330(c).  If a taxpayer received a statutory               
          notice of deficiency for the underlying tax liability or                    
          otherwise had an opportunity to dispute the underlying tax                  
          liability, he or she is precluded from challenging the existence            
          or amount of the underlying tax liability.  Sec. 6330(c)(2)(B).             
               To the extent possible, a section 6320 hearing will be held            
          in conjunction with a section 6330 hearing.  Sec. 301.6320-                 
          1(d)(1), Q&A-D3, Proced. & Admin. Regs.                                     
               This Court has jurisdiction to review the Commissioner’s               
          administrative determination under section 6330(d).  If the                 
          underlying tax liability is properly at issue, we review that               
          issue de novo.  Sego v. Commissioner, 114 T.C. 604, 610 (2000);             
          Goza v. Commissioner, 114 T.C. 176, 181 (2000).  If the validity            
          of the underlying tax liability is not at issue, we review the              
          determination for abuse of discretion.  Sego v. Commissioner,               
          supra at 610.  An abuse of discretion occurs when an Appeals                
          officer takes action that is arbitrary, capricious, or without              
          sound basis in fact or law.  See Woodral v. Commissioner, 112               
          T.C. 19, 23 (1999).                                                         
               At trial, petitioner failed to provide any evidence that               
          any of the underlying liabilities was incorrect.  She did not               
          dispute the amount of any of those liabilities.  Accordingly, we            








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