Steven and Davina Sego - Page 14




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          in cases such as this one.  The validity of the underlying tax              
          liability is not properly before the Court.                                 
               As indicated above, petitioners’ claims in part are based on           
          events occurring after the Appeals Office hearing.  Matters                 
          raised after a hearing do not reflect on whether the                        
          determinations that are the basis of this petition were an abuse            
          of discretion.  Attacks on the use of statistics to determine               
          Steven Sego’s income relate to the underlying liability and                 
          cannot be considered for the reasons set forth above.  There is             
          no explanation or challenge in the petition to the                          
          appropriateness or inappropriateness of the intended method of              
          collection, no offer of an alternative means of collection, and             
          no spousal defenses.  The petition does not assert and there is             
          no basis in the record for the Court to conclude that respondent            
          abused his discretion with respect to any of these matters.                 
               The decision in this case will indicate that we sustain                
          respondent’s administrative determination to proceed with                   
          collection against petitioners.  Our decision does not serve as a           
          review of respondent’s determination as to petitioners’                     
          underlying tax liability for 1993, 1994, or 1995.                           
               To reflect the foregoing,                                              
                                                  Decision will be entered            
                                             for respondent.                          








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