Steven G. Orr - Page 5

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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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