Gary G. Boyd - Page 8




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          suspended.  See sec. 6330(e)(1); sec. 301.6330-1T(g)(2), A-G1,              
          Temporary Proced. & Admin. Regs., 64 Fed. Reg. 3412 (Jan. 22,               
          1999).  Thus, respondent is not time barred from collecting                 
          petitioner’s Federal income tax liabilities for taxable years               
          1989 and 1990.                                                              
               Petitioner has raised no other issue concerning his Federal            
          income tax liabilities for taxable years 1989 and 1990.  We                 
          conclude that petitioner is not entitled to the relief he seeks             
          for those years.                                                            
          Has Petitioner Already Paid His Tax Liabilities for the Other               
          Taxable Years in Issue?                                                     
               Petitioner contends that he has already paid his Federal               
          income tax liabilities for taxable years 1991, 1992, 1993, 1996,            
          and 1997.  Because the validity of the underlying tax liability--           
          i.e., the amount of tax owed that remains unpaid--is properly in            
          issue for these taxable years, we review respondent’s                       
          determinations for these years de novo.  See Landry v.                      
          Commissioner, 116 T.C. 60, 62 (2001).                                       
               Respondent introduced certified transcripts of account for             
          petitioner’s Federal income taxes for each of the taxable years             
          in issue.  These transcripts reflect, among other things,                   
          petitioner’s tax liabilities for taxable years 1991, 1992, 1993,            
          1996, and 1997 and all payments received for those liabilities.             
          The transcripts show that petitioner made some payments for his             







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