- 7 - Director and also to the Director of the Service Center who issued the notices of deficiency in this case. See Stamos v. Commissioner, 95 T.C. 624, 630-631 (1990), affd. without published opinion 956 F.2d 1168 (9th Cir. 1992); Kellogg v. Commissioner, 88 T.C. 167, 172 (1987); Perlmutter v. Commissioner, 44 T.C. 382, 385 (1965), affd. 373 F.2d 45 (10th Cir. 1967); secs. 301.6212-1(a), 301.7701-9(b), Proced. & Admin. Regs. A taxpayer may contest the existence or amount of the underlying tax liability at the section 6330(b) hearing only if the taxpayer did not receive a notice of deficiency for such tax liability or did not otherwise have an opportunity to dispute such tax liability. Sec. 6330(c)(2)(B). Section 6330(c)(2)(B) bars petitioner from contesting the existence or amount of his tax liabilities for 1992-97 because he received notices of deficiency for those years. B. Whether Respondent’s Determination To Proceed With Collection as to Petitioner’s 1992-97 Tax Years Was an Abuse of Discretion The Appeals officer verified that the Internal Revenue Service (IRS) had met the requirements of any applicable laws and administrative procedures. See sec. 6330(c)(1); sec. 301.6330- 1(e)(1), Proced. & Admin. Regs. The second sentence of section 6203 provides that the Secretary shall, upon request of the taxpayer, provide the taxpayer a copy of the record of assessment.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011