-12-
As already noted, the only issue raised by petitioner at the
Appeals hearing was that the Philadelphia Service Center had
transposed numbers from the Tax Court decision documents and
refused to abate the incorrect amounts. The Appeals officer
determined that the tax, including penalties, reflected in the
Tax Court decision documents had been correctly assessed, but
that petitioner had not been credited with withholding tax for
1989, 1990, and 1992. Accordingly, the Appeals officer made
three adjustment documents for crediting petitioner with the
withholding taxes.
Because petitioner in his petition persisted in maintaining
that the IRS had made excessive and wrongful assessments, the
Court, as already discussed, directed respondent, among other
things, to explain how the liability for each year was computed,
and to demonstrate the allowance of the 1989, 1990, and 1992
withholdings, which were not taken into account in respondent’s
Levy Notice, dated March 22, 2004. Respondent’s notice of
determination, issued after the Levy Notice, properly reflects
the allowance of the withholding credits.
In petitioner’s “Opposition” to Respondent’s Supplement, he
makes no attempt whatsoever to demonstrate why he believes
respondent transposed decision document numbers, or why
respondent’s assessments are incorrect. Instead he persists in
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Last modified: May 25, 2011