- 9 - Discussion All of the arguments that petitioners have presented in this case, in one form or another, have been rejected in prior cases. Those arguments dealing with the taxability of their income are irrelevant in any event. Because they received the statutory notice of deficiency for 1996, 1997, and 1998, petitioners were not entitled to challenge their underlying tax liability at the hearing conducted under section 6330. Sec. 6330(c)(2)(B). They did not raise any bona fide issues or collection alternatives at the hearing, and they have not raised any genuine issues in this case. There was no abuse of discretion with respect to the determination that collection should proceed. Numerous cases establish that no particular form of verification is required, that no particular document need be provided to taxpayers at a hearing conducted under section 6330, and that Form 4340 provided to the taxpayers after the hearing satisfies the requirements of section 6330(c)(1). See, e.g., Roberts v. Commissioner, supra; Nestor v. Commissioner, 118 T.C. 162, 167 (2002); Hauck v. Commissioner, supra; Kuglin v. Commissioner, T.C. Memo. 2002-51. Scores of cases have disposed of claims indistinguishable from petitioners’ claims by summary judgment, with imposition of a penalty under section 6673. See, e.g., Roberts v. Commissioner, supra; Hill v. Commissioner, T.C. Memo. 2003-144; Holguin v. Commissioner, T.C. Memo. 2003-125;Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011