- 11 - 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”.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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