Steven G. Orr - Page 4

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                                        OPINION                                       
               Section 6330 provides that, upon request and in the                    
          circumstances described therein, a taxpayer has a right to a                
          hearing which consists of the following elements:  (1) An                   
          impartial officer will conduct the hearing; (2) the conducting              
          officer will receive verification from the Secretary that the               
          requirements of applicable law and administrative procedure have            
          been met; (3) certain issues may be heard such as spousal                   
          defenses and offers-in-compromise; and (4) a challenge to the               
          underlying liability may be raised if the taxpayer did not                  
          receive a statutory notice of deficiency or otherwise receive an            
          opportunity to dispute the liability.  Sec. 6330(c).                        
               Concerning the tax years under consideration, petitioner               
          already had an opportunity, before this Court and the Court of              
          Appeals for the Ninth Circuit, to question the underlying merits            
          of the income tax deficiencies for 1995 and 1996.  Accordingly,             
          petitioner is not entitled to contest the underlying merits of              
          his 1995 and 1996 income tax liabilities.  See sec.                         
          6330(c)(2)(B); Sego v. Commissioner 114 T.C. 604 (2000); Goza v.            
          Commissioner, 114 T.C. 176 (2000).                                          
               Petitioner has not raised any arguments other than those               
          that question the merits of his liabilities; i.e., he raised no             
          issues about the conduct of the hearing or verification that                
          administrative procedures had been followed, or about collection            






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