- 32 -
Thus, respondent deprived petitioner of his right to raise
relevant issues relating to the assessments. See sec.
6330(c)(2). The appropriate remedy is to have a further hearing
on this matter. The majority may wonder what “bona fide interest
would be served”. In short, the “bona fide interest” served is
compliance with the provisions of section 6330.
CHIECHI, J., agrees with this dissenting opinion.
Page: Previous 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 Last modified: May 25, 2011