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asserts that respondent may not assess tax because section 6201
provides for self-assessment and only petitioner can determine
what tax he owes.
Petitioner’s contentions are frivolous. There is no
requirement that the notice of intent to levy identify the Code
sections which establish the taxpayer’s liability for tax,
additions to tax, or penalties.
Section 6330(c)(2)(A) permits a taxpayer to challenge the
appropriateness of the intended method of collection, offer
alternatives to collection, or raise a spousal defense to
collection. Petitioner gives no bona fide basis for his claim
that the collection action was not appropriate. We conclude that
respondent’s determination to proceed with collection of the tax
liabilities assessed against petitioner for those years was not
an abuse of discretion.4
Accordingly,
An appropriate order
will be issued.
Reviewed by the Court.
WELLS, COHEN, GERBER, RUWE, WHALEN, HALPERN, and THORNTON,
JJ., agree with this majority opinion.
MARVEL, J., concurs in result only.
4 We also hold herein that petitioner’s contentions
discussed in par. B (slip op. pp. 7-10) lack merit for years
1990-91.
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