Charles and Teresa Brodman - Page 9

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                                     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;               






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