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Matters--for each year and determined that the IRS had mailed
valid assessment and demand notices. She also looked at
collection alternatives, but her review of IRS records showed
that petitioner had not filed an income tax return since at least
1994. Thus, following 2 Administration, Internal Revenue Manual
(CCH), sec. 5.8.3.2, at 16,281, she did not pursue any collection
alternatives.
After the hearing, the IRS sent petitioner a notice of
determination that it would proceed with collection; petitioner
then petitioned for review.
Discussion
In his petition, petitioner made barebones assertions that
the IRS had failed to offer him a fair and impartial hearing,
failed to provide a fair and impartial officer, and failed to
follow its own procedures. He also renewed his objection to the
adequacy of the notices of assessment and demands for payment
that respondent had sent him.
Respondent denied these allegations and now moves for
summary judgment.
Because this Court has already decided the question of
petitioner’s tax liability in its 2000 decision, that liability
is no longer at issue, and we will review respondent’s
determination for abuse of discretion. See Davis v. Commissioner,
115 T.C. 35, 39 (2000).
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Last modified: May 25, 2011