118 T.C. No. 30 UNITED STATES TAX COURT RAYMOND B. MAGANA, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 10306-00L. Filed May 31, 2002. Held: Under sec. 6330(c)(4), I.R.C., in this judicial proceeding involving respondent’s proposed collection activity, petitioner is precluded from relitigating a statute of limitations issue that was previously adjudicated in a related District Court proceeding. Respondent’s motion for summary judgment with regard thereto is granted. Held, further, in our review for an abuse of discretion under sec. 6330(d)(1), I.R.C., of respondent’s determination, generally we consider only arguments, issues, and other matter that were raised at the collection hearing or otherwise brought to the attention of the Appeals Office. This case does not involve an allegation of recent, unusual illness or hardship, or other special circumstance, that might cause us to make an exception to the general rule set forth herein and to consider petitioner’s new hardship argument.Page: 1 2 3 4 5 6 7 8 9 10 11 Next
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