Carl and Lisa Neugebauer - Page 6

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          standard where the validity of the underlying tax liability is at           
          issue.  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).  The Court will           
          review the Commissioner’s administrative determination for abuse            
          of discretion with respect to all other issues.  Sego v.                    
          Commissioner, 114 T.C. 604, 610 (2000).                                     
               Here, petitioners do not dispute the existence or the amount           
          of an underlying tax liability.  Therefore, the proper standard             
          for our review of respondent’s determination is abuse of                    
          discretion.  Under section 6330(c)(3), the determination of an              
          Appeals officer must take into consideration (A) the verification           
          that the requirements of applicable law and administrative                  
          procedures have been met, (B) issues raised by the taxpayer, and            
          (C) whether any proposed collection action balances the need for            
          the efficient collection of taxes with the legitimate concern of            
          the person that any collection be no more intrusive than                    
          necessary.                                                                  
               Here, the Appeals officer addressed all these matters.                 
          He satisfied the first requirement by reviewing the Internal                
          Revenue Service transcripts of petitioners’ account.  Hill v.               
          Commissioner, T.C. Memo. 2002-272; Kuglin v. Commissioner, T.C.             
          Memo. 2002-51; Weishan v. Commissioner, T.C. Memo. 2002-88.                 






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