Curtis B. Keene - Page 11




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          those years.7                                                               
               At the hearing, petitioner acknowledged receiving the                  
          transcripts that the Appeals officer had previously mailed to               
          him.  Nevertheless, petitioner alleged that those transcripts               
          were unreliable because they failed to reflect that notices of              
          deficiency for 1997 and 1998 had been sent to him.  Petitioner              
          also complained that he was being denied the right to separate              
          hearings for each of the two taxable years in issue; he also                
          insisted on revisiting the audit phase of his case and                      
          challenging the existence or amount of his underlying tax                   
          liabilities.  The Appeals officer explained that because                    
          petitioner had actually received notices of deficiency for 1997             
          and 1998 but had not filed a petition for redetermination with              
          the Tax Court, petitioner was precluded from challenging the                
          existence or amount of his underlying tax liabilities for those             
          years at the hearing.  The Appeals officer also explained that              
          his review of petitioner’s transcripts of account for 1997 and              
          1998 was sufficient to satisfy the verification requirement of              
          section 6330(c)(1) that all applicable laws and administrative              
          procedures had been followed in the assessment and collection               
          process.  Ultimately, after repeatedly offering to consider any             
          collection alternatives that petitioner might care to offer, and            


               7  A literal transcript is a transcript in “plain English”             
          with a minimum amount of “computerese”.                                     





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