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alternatives. Petitioner submitted voluminous materials,
including his testimony concerning his employment by the
Department of the Treasury and his claim that he was a “whistle
blower”. Petitioner contends that the Department of the Treasury
has conspired with the Internal Revenue Service to pursue
petitioner by harassing him with income tax matters. Petitioner
also believes that the Federal court system has participated in
some form of Government collusion against him. The provisions of
section 6330 do not provide petitioner with a forum in this
proceeding to address such matters. Simply, petitioner’s
allegations, if proven, go to the underlying merits of his 1995
and 1996 tax liabilities, and under section 6330(c)(2)(B),
petitioner is precluded from raising the merits where he already
had an opportunity to do so.
Respondent has provided petitioner with a section 6330
hearing, and petitioner has not shown an abuse of discretion by
respondent. Accordingly, we hold that respondent did not abuse
his discretion in determining to proceed with enforced collection
of petitioner’s 1995 and 1996 income tax liabilities.
To reflect the foregoing,
Decision will be entered
permitting respondent to proceed
with collection.
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Last modified: May 25, 2011