-10- 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 toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011