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grounds are insufficient to challenge respondent’s intent to levy
and the filing of notices of lien.
Section 6330(c)(2)(A) permits taxpayers to raise any
relevant issue, including spousal defenses to collection,
challenges to the appropriateness of the Commissioner’s intended
collection action, and offers of alternative means of collection.
Petitioner does not seek that type of relief permitted and is
prohibited from questioning the underlying deficiencies because
of the issuance and receipt of the prior notices of deficiency
for the same taxable years. See sec. 6330(c)(2)(B).
Accordingly, respondent’s motion to dismiss for lack of
jurisdiction will be denied, and petitioner’s action will be
dismissed for petitioner’s failure to state a claim upon which
relief can be granted.
To reflect the forgoing,
An appropriate order and decision
will be entered.
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Last modified: May 25, 2011