Sue Taylor - Page 5

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          without the opportunity for a taxpayer to seek an administrative            
          review of the proposed levy and filed lien and/or the opportunity           
          for judicial review of the administrative determination to                  
          proceed with collection.  Davis v. Commissioner, 115 T.C. 35, 37            
          (2000).                                                                     
               Petitioner opted for an administrative review and, after               
          respondent’s determination to go forward with collection, sought            
          review by this Court.  Petitioner did not file a petition for her           
          1997 tax year following respondent’s issuance of a statutory                
          notice of deficiency.  Accordingly, petitioner is afforded review           
          by this Court solely on the question of abuse of discretion                 
          because the validity of the underlying liability is not at issue.           
          Sec. 6330(c)(2)(B); Sego v. Commissioner, 114 T.C. 604, 610                 
          (2000).                                                                     
               Because petitioner is not entitled to question the                     
          underlying tax liability, her administrative review was limited             
          to collection issues, including spousal defenses, the                       
          appropriateness of respondent’s intended collection action, and             
          possible alternatives to collection.  Sec. 6330(c)(2). However,             
          when the hearing date arrived, neither petitioner nor her                   
          designated representative appeared for the scheduled conference,            
          and neither one had attempted to schedule an alternative                    
          conference date.                                                            








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