Mehdi H. Hajiyani - Page 6

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          be questioned, and we review respondent’s determination under an            
          abuse of discretion standard.                                               
               The main thrust of petitioner’s challenge concerns the                 
          computations in the deficiency proceeding under Rule 155.                   
          However, as noted, petitioner is not entitled to question the               
          underlying tax liabilities because he already has been provided             
          the opportunity to challenge his liabilities.  See sec.                     
          6330(c)(2)(B).  In that regard, petitioner was provided with the            
          opportunity to submit a computation under Rule 155, but failed to           
          timely do so. Petitioner contends that Mr. Wall, his attorney,              
          did not submit a Rule 155 computation.  Petitioner’s contention             
          with respect to his attorney’s failure does not change the                  
          limitation upon petitioner or the Court with respect to                     
          addressing the underlying merits of his 1993 or 1994 tax                    
          liability.  See sec. 6330(c)(2)(B).                                         
               With respect to petitioner’s second argument, concerning his           
          attempted offer-in-compromise, our review of the Commissioner’s             
          determination generally is limited to issues raised at the                  
          section 6330 hearing.  Magana v. Commissioner, 118 T.C. 488, 493            
          (2002).  Petitioner’s offer-in-compromise was submitted after the           
          scheduled section 6330 hearing and the issuance of the final                
          notice.  Accordingly, the offer-in-compromise could not have been           
          considered at the section 6330 hearing.  There would, therefore,            







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