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did not receive any statutory notice of
deficiency for such tax liability or did not
otherwise have an opportunity to dispute such
tax liability.
Moreover, except in certain limited circumstances, a person is
generally precluded from raising at the Appeals Office hearing
any issue raised and considered in any previous administrative or
judicial proceeding. Sec. 6330(c)(4).
B. Petitioners’ Challenges to Their Underlying Tax Liabilities
In this collection proceeding, petitioners challenge their
underlying tax liabilities as transferees of the corporation for
its 1995 tax liability. More particularly, having previously
agreed to this Court’s stipulated decisions in the transferee
liability cases, petitioners now seek in this collection
proceeding to repudiate those stipulated decisions on various
grounds. They argue, among other things, that respondent’s
notice of deficiency to the corporation was invalid and that
consequently this Court’s stipulated decisions in the
corporation’s deficiency case and in the transferee liability
cases were jurisdictionally defective. Petitioners also contend
that the stipulated decisions in the transferee liability cases
failed to take into account certain of the corporation’s
liabilities (apparently because petitioners failed to assert them
in the transferee liability cases), which, if considered, would
more than offset the value of any assets the corporation
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Last modified: May 25, 2011