Peter D. Dahlin Attorney at Law, P.S. - Page 10




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          warrant further consideration of the merits of its case by the              
          Appeals Office or this Court.  Petitioner focused its argument on           
          the fact that it was not provided a face-to-face hearing, nor               
          Form 4340 with a 23C date prior to the issuance of the notice of            
          determination, as requested.  The Court concludes that all                  
          pertinent issues relating to the underlying corporate tax                   
          liability and the propriety of the collection determination can             
          be decided based on the present record.                                     
          III. Standard of Review                                                     
               At issue in this case is respondent’s right to collect                 
          petitioner’s self-determined tax liability for 2000 (i.e., the              
          amount set forth on petitioner’s filed 2000 Form 1120-X).  A                
          taxpayer’s challenge to his self-determined tax liability at an             
          Appeals Office hearing constitutes a permissible challenge to the           
          underlying tax liability under section 6330(c)(2)(B).  Montgomery           
          v. Commissioner, 122 T.C. 1, 9 (2004).  Petitioner contends that            
          this Court should review the instant case de novo, stating:  “The           
          Petitioner filed the 1120 tax return and self-assessed the tax              
          without any judicial determination.”  However, petitioner is not            
          disputing the accuracy of its self-determined tax liability.  See           
          supra note 4.  Instead, petitioner argues that it should have had           
          a face-to-face hearing, with which the Court has already                    
          indicated its disagreement, and, as discussed and addressed                 








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