- 5 - 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.Page: Previous 1 2 3 4 5
Last modified: May 25, 2011