- 29 - return on the ground he “did not otherwise have an opportunity to dispute such tax liability” within the meaning of section 6330(c)(2)(B). We need not and do not answer this question posed by the parties in this proceeding for the tax years 1994 and 1996. Because petitioner failed to take advantage of any of the numerous opportunities he was afforded to specify his alleged losses and the years in which they occurred and to introduce evidence in support of them, we leave the resolution of this question to another day. Petitioner Failed To Show His Right to Deductions Petitioner failed to state and quantify his claims for loss deductions in either his request for a section 6330 hearing or in his petition to this Court. He was unable to make the Appeals officer understand his claims for any of the years in issue, and he failed to introduce any evidence in support of his claims at the section 6330 hearing. Petitioner failed to file a brief in answer to respondent’s opening brief, as he had been ordered to do in the Court-ordered briefing schedule.11 However, we need not reject petitioner’s contention on any of the foregoing grounds. Cf. Aguirre v. Commissioner, 117 T.C. 324, 327 (2001). 11Petitioner’s failure to file a brief would suffice to reject petitioner’s contention. See Rule 123; Stringer v. Commissioner, 84 T.C. 693, 704-705 (1985), affd. 789 F.2d 917 (4th Cir. 1986); see also Petzoldt v. Commissioner, 92 T.C. 661, 603 (1989); Money v. Commissioner, 89 T.C. 46, 48 (1987).Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
Last modified: May 25, 2011