- 14 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14
Last modified: May 25, 2011