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.
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