Howard Goza - Page 12

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          Court pursuant to section 6213(a).  Consistent with section                    
          6330(c)(2)(B), petitioner therefore was precluded from contesting              
          his liability for the underlying taxes before the Appeals Office.              
          Respondent's determination letter states that respondent                       
          explained the effect of section 6330(c)(2)(B) to petitioner in a               
          letter dated July 6, 1999.  Nevertheless, petitioner persisted in              
          arguing before the Appeals Office that he was not liable for the               
          underlying taxes on constitutional grounds.                                    
               While ignoring the proscription of section 6330(c)(2)(B),                 
          petitioner likewise failed to assert before the Appeals Office                 
          any of the claims enumerated under section 6330(c)(2)(A).  In                  
          particular, petitioner did not challenge the appropriateness of                
          the intended method of collection, offer an alternative means of               
          collection, or raise a spousal defense to collection as directed               
          under section 6330(c)(2)(A).  Nor has he raised any such issue                 
          before the Court.                                                              
               Rule 331(b)(4) states that a petition for review of an                    
          administrative determination filed pursuant to section 6330 shall              
          contain clear and concise assignments of each and every error                  
          which the petitioner alleges to have been committed in the levy                
          determination and any issue not raised in the assignments of                   
          error shall be deemed to be conceded.  Rule 331(b)(5) states that              
          such a petition shall contain clear and concise lettered                       

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