- 8 - the information required in order to consider an alternative collection action. Throughout the proceeding, petitioner’s conduct demonstrates propensity to cause delay in collecting his outstanding tax liabilities. We sustain respondent’s determination regarding the proposed levy as a permissible exercise of discretion. We note as to the allegations set forth in the petition that petitioner did receive a hearing under section 6330, that petitioner was given an opportunity to participate in the proceeding relating to an offer in compromise, and that petitioner’s unsupported allegations raise no triable issue of fact concerning “punitive conduct” by the IRS personnel. Regarding the petitioner’s request to refer this case to a different forum, we observe that this Court has jurisdiction over the appeal of the administrative determinations where the underlying tax liability concerns unpaid income taxes, as opposed to certain other taxes. See, e.g., Goza v. Commissioner, supra at 182. We decline to grant the petitioner’s request. We have considered all arguments raised by the parties and have found those arguments not discussed herein to be irrelevant and/or without merit. Accordingly, An appropriate order and decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8
Last modified: May 25, 2011