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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.
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Last modified: May 25, 2011