Filomena Pahamotang - Page 10

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          respondent’s determination to partially grant and deny section              
          6015 relief to petitioner.                                                  
               Petitioner engaged in an extensive dialog with two different           
          Appeals officers, and she received consideration of all issues              
          raised, even though some were not as a matter of right under                
          section 6330(b).  In addition to the assignment of one Appeals              
          officer to provide a section 6330 hearing, respondent assigned a            
          second Appeals officer to consider petitioner’s claim for relief            
          under section 6015.  With respect to a section 6330 hearing, one            
          Appeals officer granted some relief with respect to the                     
          underlying merits, even though petitioner was not entitled to               
          question the underlying merits under section 6330.  With respect            
          to petitioner’s claim for section 6015 relief, she was afforded             
          $33,378 of the $45,617 in relief she requested.  Petitioner asks            
          this Court to review respondent’s failure to grant relief with              
          respect to the $12,239 balance, but she has provided no evidence            
          or specific argument upon which we could hold that she is                   
          entitled to such relief.  She received a substantial amount of              
          relief from the outstanding 1994 income tax liability                       
          (approximately 75 percent of the relief she requested).                     
               Petitioner was also offered a collection alternative in the            
          form of installment payments, which she declined.  Petitioner               
          claims that respondent has abused his discretion because he did             
          not consider additional questions as to the merits of the 1994              






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