Carl R. Neugebauer - Page 8

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          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.                                   






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