- 2 - Held: P received an adequate opportunity for an Appeals hearing pursuant to sec. 6320(b), I.R.C. In any event, the communications between the Appeals officer and P constituted an Appeals hearing under sec. 6320(b), I.R.C. Held, further, P’s challenge to the merits of R’s assessment of the tax deficiency and additions to tax fails to state a claim on which relief can be granted. Held, further, because the Court has jurisdiction under sec. 6404(i), I.R.C., over interest abatement cases, the Court has jurisdiction to review the Appeals officer’s determination with regard to the interest that is the subject of R’s collection activities. However, the Appeals officer did not abuse his discretion in making the determination. Scott W. Katz, pro se. Kenneth A. Hochman and John T. Lortie, for respondent. OPINION VASQUEZ, Judge: Petitioner filed a petition in response to respondent’s Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination).1 In his petition, petitioner alleges that the Internal Revenue Service Office of Appeals (Appeals Office) failed to hold a meaningful hearing as required by section 6320(b) (Appeals hearing). Petitioner further challenges the merits of a tax deficiency and additions to tax previously 1 Unless otherwise indicated, all section references are to the Internal Revenue Code as amended, and all Rule references are to the Tax Court Rules of Practice and Procedure.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011