Curtis J.L. McIntosh - Page 9

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          action, and possible alternative means of collection.  A taxpayer           
          may contest the existence or amount of the underlying tax                   
          liability at an Appeals Office hearing only if the taxpayer did             
          not receive any statutory notice of deficiency for the tax                  
          liability or did not otherwise have an opportunity to dispute the           
          tax liability.  Sec. 6330(c)(2)(B); see Sego v. Commissioner, 114           
          T.C. 604, 609 (2000); Goza v. Commissioner, 114 T.C. 176, 180-181           
          (2000).  Moreover, except in certain limited circumstances, a               
          person is generally precluded from raising at the Appeals Office            
          hearing any issue raised and considered in any previous                     
          administrative or judicial proceeding.  Sec. 6330(c)(4).                    
               Where the validity of the underlying tax liability is                  
          properly at issue, we review that issue de novo.  See Sego v.               
          Commissioner, supra at 610.  Other issues we review for abuse of            
          discretion.  Id.  On brief, petitioner acknowledges that he “has            
          not challenged the validity of the tax liability” and that we               
          should review respondent’s determination in this collection                 
          proceeding for abuse of discretion.                                         
          B.  Verification Requirement                                                
               Petitioner contends that the Appeals officer failed to                 
          obtain verification from the Secretary that the requirements of             
          all applicable laws and administrative procedures had been met as           
          required by section 6330(c)(1).                                             
               Section 6330(c)(1) does not require the Commissioner to rely           






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