- 9 - after section 6330's effective date. See Goza v. Commissioner, supra at 182-183 (holding that receipt of a notice of deficiency issued prior to January 19, 1999, precluded the taxpayer from challenging the underlying liability). We need not decide whether review of Appeals’ denial of the extension request is precluded by section 6330(c)(4) because the Appeals’ denial was raised by the estate and reconsidered by respondent. Indeed, respondent stated in the determination: “We have reconsidered your request for extension of time to pay and have concluded that the decision of the appellate conferee was correct and not an abuse of discretion.” In sustaining the extension denial, the Appellate conferee asserted his objection to allowing distributions to the beneficiary prior to payment of the estate’s tax liability, and found unpersuasive the estate’s contention that it could not pay the estate tax liability because it could not “borrow * * * except at a rate of interest higher than that generally available”. Respondent’s refusal to reverse the Appellate conferee’s decision was not an abuse of discretion. II. The Request for Abatement The estate contends that it was entitled to raise, and have considered at the hearing, its request for abatement. Respondent contends that this issue could not be raised during the hearing because the estate took advantage of the opportunity to challengePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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