Scott William Katz - Page 2




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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