- 4 - Determination Concerning Collection Action(s) Under Section 6320 and/or 6330 concluding that the liabilities set forth above were correct and unpaid and that the filing of the tax lien was appropriate. The Appeals officer also determined that a consideration of any offer in compromise was inappropriate because petitioner had not filed tax returns for subsequent years. Petitioner timely filed with this Court a petition for review of the Appeals officer’s determinations. Petitioner raised only the question of whether the liabilities had been paid. Discussion Respondent did not issue petitioner notices of deficiency for the taxable years at issue, and petitioner has not had an opportunity to dispute whether such tax liabilities remain unpaid. Petitioner may challenge the existence of the underlying tax liabilities in this Court. See secs. 6320(c), 6330(c)(2)(B), (d). Where the validity of the underlying tax liabilities is properly placed at issue, this Court will review the matter on a de novo basis. Sego v. Commissioner, 114 T.C. 604, 610 (2000); Goza v. Commissioner, 114 T.C. 176, 181-182 (2000). Section 6511 contains two separate provisions to determine the period of limitations for refund or credit claims. First, section 6511(a) establishes a filing deadline. Second, section 6511(b)(2)(A) establishes a “look-back” period, which provides aPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011