- 4 - On September 18, 2000, respondent mailed petitioner a Notice of Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 (notice of determination) for 1990 through 1998. Respondent determined (1) the requirements of applicable law and administrative procedures had been met, (2) petitioner did not dispute the correctness of the underlying liabilities for the years in issue, and (3) to proceed with collection. OPINION At trial, petitioner admitted that he did not dispute the underlying liability at the section 6330 hearing; however, at trial and on brief petitioner attempted to claim he was entitled to additional deductions for some of the years in issue. We reject this claim for the following reasons: (1) For 1990 and 1992 he is prevented from disputing his underlying liabilities because respondent and petitioner reached an agreement as to additional liabilities and these amounts were assessed, Aguirre v. Commissioner, 117 T.C. 324, 327 (2001), and (2) petitioner presented no credible evidence that his underlying liabilities for any of the years in issue were incorrect. Smith v. Commissioner, T.C. Memo. 2002-59. Prior to 1994, petitioner owned the Emerson house. During 1994, Fleet foreclosed on the Emerson house. Fleet received all the proceeds of the foreclosure sale. Petitioner sued Fleet andPage: Previous 1 2 3 4 5 6 7 8 Next
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