Larry A. Michael - Page 10




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          determination.  Davis v. Commissioner, 115 T.C. 35, 37 (2000);              
          Goza v. Commissioner, 114 T.C. 176, 179 (2000).  In the event of            
          such a judicial review, the Court’s standard of review depends on           
          whether the underlying tax liability is at issue.  The Court                
          reviews a taxpayer’s liability under the de novo standard where             
          the validity of the underlying tax liability is at issue.  The              
          Court reviews other administrative determinations for abuse of              
          discretion.  Sego v. Commissioner, 114 T.C. 604, 610 (2000).  A             
          taxpayer’s underlying tax liability may be at issue if he or she            
          “did not receive any statutory notice of deficiency for such tax            
          liability or did not otherwise have an opportunity to dispute               
          such tax liability.”  Sec. 6330(c)(2)(B).                                   
               Here, respondent notified petitioner that he was proposing             
          to levy upon petitioner’s property in order to collect                      
          petitioner’s Federal income tax debt for 1994, 1995, and 1996.              
          Following the determination by Appeals that respondent’s proposed           
          levy was proper, petitioner sought relief in this Court.  In                
          order to decide this case, we focus on assignments of error set             
          forth in the petition that commenced this proceeding.  Rule                 
          331(b)(4) (“Any issue not raised in the assignments of error                
          shall be deemed to be conceded.”).                                          
               Petitioner asserts in his petition numerous allegations of             
          error in the Appeals officer’s determination.  Many of these                
          allegations are either frivolous and groundless or irrelevant to            






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