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statutory requirements have been met”; (2) petitioner’s
“allegations that the tax is not owed are unsubstantiated”; and
(3) “the proposed collection methods are not too intrusive”. In
the notice, respondent also notes that petitioner “raised the
issue” of the amount or the existence of his 1988 Federal income
tax liability, but that he failed to present “anything to change
the amount of tax assessed”, and further, that petitioner offered
“no other alternatives to enforced collection”.
Discussion
Petitioner’s incarceration prevented him from attending
either of the scheduled hearings with the Appeals officer. We
could remand the case to respondent’s Appeals Office to allow for
an administrative hearing, see, e.g., Tatum v. Commissioner, T.C.
Memo. 2003-115; Nestor v. Commissioner, T.C. Memo. 2002-251;
however, under the circumstances we elect not to do so.
Petitioner makes no claim that the Appeals officer failed to
obtain verification that the requirements of any applicable law
or administrative procedure have been met. See 6330(c)(1).
Furthermore, petitioner does not raise a spousal defense,
challenge the appropriateness of the proposed collection action,
or offer any collection alternatives. See sec. 6330(c)(2)(A).
Instead, petitioner’s challenge to respondent’s determination
raises issues exclusively related to the existence or amount of
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