Alan R. Wylie - Page 3

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          Hearing.  The levy related to his unpaid liability for income tax           
          assessments for 1993, 1994, and 1995.  Petitioner requested and             
          was granted a collection due process hearing which was held on              
          May 12, 2000.  Other than objecting that the Form 4340,                     
          Certificate of Assessment and Payments, was not a proper basis to           
          verify the assessments petitioner raised no other arguments and             
          offered no collection alternatives.  On May 19, 2000, respondent            
          UNDER SECTION 6320 AND/OR 6330” to petitioner (notice of                    
          determination).  The notice of determination states: “The                   
          Collection enforcement action proposed is the appropriate action            
          in this case.”                                                              
               Petitioner timely filed a petition seeking judicial review             
          of that determination.  Where the validity of the underlying tax            
          liability is properly at issue, the Court will review the matter            
          de novo.  Where, as is here, the underlying liability is not at             
          issue, the Court will review the Commissioner's administrative              
          determination for abuse of discretion.  See Sego v. Commissioner,           
          114 T.C. 604, 610 (2000).                                                   
               Petitioner alleges in the petition that respondent made the            
          following errors in making his determination:                               
               (a) The appeals officer failed to get proper                           
               verification from the Secretary that the service met                   
               the requirements of any applicable law or                              
               administrative procedure as required by �6330(c)(1), 26                
               CFR �301.6320-T(e)(1)[sic] and 26 CFR �301.6330-                       

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