Robert Holliday - Page 9

                                        - 9 -                                         
          (2002), affd. 329 F.3d 1224 (11th Cir. 2003); Davis v.                      
          Commissioner, 115 T.C. 35 (2000).  Respondent also properly                 
          notified petitioner of the assessments by issuing a notice of               
          balance due for each taxable year.  See, e.g., Hughes v. United             
          States, 953 F.2d 531, 536 (9th Cir. 1992).                                  
               Petitioner’s meritless arguments support the conclusion that           
          remanding this matter to respondent’s Appeals Office for                    
          recording would be neither necessary nor productive, and we so              
          hold.                                                                       
               We have considered all of petitioner’s contentions and                 
          arguments that we have not discussed, and we find them to be                
          without merit and irrelevant.                                               
               Further, we hold that respondent correctly determined that             
          collection efforts should proceed.                                          
               To reflect the foregoing,                                              


                                             Decision will be entered                 
                                        for respondent.                               
















Page:  Previous  1  2  3  4  5  6  7  8  9  

Last modified: May 25, 2011