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the date they were issued, the assessments for 1990 are
valid.
I. Petitioner Seeks Review in Wrong Court
On August 18, 2000, petitioner filed a complaint in the
District Court seeking review of respondent’s determination to
proceed with collection of his 1990 taxes. On July 11, 2001, the
District Court dismissed the complaint with prejudice for lack of
subject matter jurisdiction.
J. Tax Court Petition
On August 14, 2001, petitioner timely petitioned this Court
to review respondent’s determination to proceed with collection
of his 1990 taxes. In his petition, petitioner claims that: (1)
No one representing the IRS attended the Appeals Office hearing;3
(2) the Appeals officer “did not obtain verification at the
hearing from the Secretary indicating that the requirements of
any applicable law or administrative procedure had been met as
required by 26 U.S.C. �6330(c)(1), nor was petitioner shown any
such evidence”; (3) respondent did not issue a notice of
assessment and demand for payment as required by section 6303;
and (4) respondent has already received payment for petitioner’s
1990 tax liabilities.
3 Petitioner did not raise this issue at trial or on brief;
therefore, we deem petitioner to have abandoned it. See Burbage
v. Commissioner, 82 T.C. 546, 547 n.2 (1984), affd. 774 F.2d 644
(4th Cir. 1985); Wolf v. Commissioner, T.C. Memo. 1992-432, affd.
13 F.3d 189 (6th Cir. 1993).
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