David M. Priestly, Jr. - Page 7

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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”.                             
               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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