Terry K. Mann - Page 5




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          issues including: Appropriate spousal defenses, challenges to the           
          appropriateness of the collection actions, and offers of                    
          collection alternatives.  Challenges to the underlying liability            
          may be raised if the taxpayer did not receive a statutory notice            
          of deficiency or otherwise have an opportunity to dispute the               
          underlying liability.  Judicial review of the Appeals officer’s             
          administrative determination is available in this Court, or if              
          this Court lacks jurisdiction over the type of tax underlying the           
          liability, in the appropriate U.S. District Court.   See sec.               
          6330(d).                                                                    
          Issue 1.  Verification of the Existence of an Assessment                    
               Petitioner contends that the Appeals officer’s reliance upon           
          the computer transcript to verify the existence of an assessment            
          does not comply with section 6330(c)(1).  In relevant part,                 
          section 6330(c)(1) provides “the appeals officer shall at the               
          hearing obtain verification from the Secretary that the                     
          requirements of any applicable law or administrative procedure              
          have been met.”  Respondent contends that the Appeals officer               
          satisfied this requirement by reviewing the computer transcript             
          to verify the existence of an assessment.  Petitioner has not               
          shown any irregularities in the assessment procedure.  In this              
          case, reliance upon the computer transcript to verify the                   
          existence of an assessment was not an abuse of discretion.                  








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