- 10 - deficiency and exhausted his opportunity to contest the tax liability. Aguirre v. Commissioner, 117 T.C. 324 (2001). Thus, petitioner may not challenge the tax deficiencies relating to 1984 and 1985 and the estimated tax and civil fraud penalties relating to 1984 through 1988. Sec. 6330(c)(2)(B); Aguirre v. Commissioner, supra. Petitioner self-assessed his tax liability relating to 1986 through 1992, 1994, and 1997. Moreover, he did not present any evidence or credible testimony disputing the amount of the underlying tax liabilities.4 Accordingly, we sustain respondent’s determination relating to 1986 through 1992, 1994, and 1997. B. Administrative Determination Prior to trial, respondent provided petitioner with Forms 4340 relating to 1984 through 1992, 1994, and 1997, and petitioner did not show any irregularity in the assessment procedure that would raise a question about the validity of these assessments. Nestor v. Commissioner, supra. Accordingly, we conclude that respondent did not abuse his discretion in determining to proceed with collection with respect to 1984 through 1992, 1994, and 1997. 4 Sec. 7491 is not applicable to this case because the examination began before the statute's effective date. Thus, petitioner had the burden of proof. Welch v. Helvering, 290 U.S. 111, 115 (1933).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
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