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Petitioner opted for an administrative appeal and, after
respondent’s decision to go forward with collection, sought
review by this Court. Petitioner did not file a petition for his
1992 tax year or perfect his petition for his 1997 tax year
following respondent’s issuance of the notices of deficiency.
Accordingly, petitioner is afforded review by this Court solely
on the question of abuse of discretion because the validity of
the underlying liabilities is not at issue. Sec. 6330(c)(2)(B);
Sego v. Commissioner, 114 T.C. 604, 610 (2000).
Because petitioner is not entitled to question the
underlying tax liability, his administrative hearing was limited
to collection issues, including spousal defenses, the
appropriateness of respondent’s intended collection action, and
possible alternatives to collection. Petitioner questioned the
appropriateness of respondent’s proposed collection action by
questioning whether the Appeals officer had satisfied the
verification requirement of section 6330(c)(1). Petitioner
contends that respondent used incorrect forms for the notice and
demand and otherwise failed to meet the requirement because the
Secretary did not personally verify the liability.
At the administrative Appeals conference, petitioner was
provided with a transcript of his tax accounts detailing the
information underlying the assessment of the taxes in question.
Petitioner does not question whether all of the steps had been
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Last modified: May 25, 2011