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Notices of Deficiency,3 so the validity of the underlying tax
liabilities for 1996 and 1997 was not properly at issue in the
administrative hearing, and is not at issue here. With respect
to his 1995 tax liability, which petitioner reported but did not
pay, he has not argued or shown that the amount reported by him
is in error. Accordingly we review here whether respondent’s
administrative determination to proceed with collection is an
abuse of discretion. Sec. 6330(c)(2)(B); Sego v. Commissioner,
114 T.C. 604, 610 (2000).
At his administrative hearing, petitioner disputed 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 also
questioned whether respondent met various statutory requirements
which petitioner contended were a prerequisite to collection.
Petitioner contends that the forms used by respondent were
improper and did not constitute notice and demand. Petitioner
also contends that the lack of personal verification by the
Secretary or a person shown to be authorized to exercise the
Secretary’s authority was a flaw that should preclude respondent
from proceeding with collection.
At the Appeals hearing, petitioner was provided with
transcripts of his accounts, which included detailed information
3 Petitioner acknowledged receipt of the notices.
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Last modified: May 25, 2011