Jeffrey M. Young - Page 9




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          makes him “liable” for income taxes or requires him “to pay”                
          income taxes.  We have consistently rejected this type of                   
          frivolous, tax-protester argument, and we perceive no reason, nor           
          are we required, to address such contentions.  See, e.g., Crain             
          v. Commissioner, 737 F.2d 1417 (5th Cir. 1984); Keene v.                    
          Commissioner, T.C. Memo. 2002-277; Hall v. Commissioner, T.C.               
          Memo. 2002-267.  We address petitioner’s remaining contentions to           
          determine whether the Appeals officer abused his discretion.  See           
          Nicklaus v. Commissioner, 117 T.C. 117, 120 (2001).                         
               Section 6330(c)(1) requires the Appeals officer to verify              
          that the requirements of any applicable law or administrative               
          procedure have been met.  However, section 6330(c)(1) does not              
          require the Appeals officer to rely on a particular document to             
          satisfy his verification function.  Kuglin v. Commissioner, T.C.            
          Memo. 2002-51.  Further, that section does not require the                  
          Appeals officer to provide a copy of the verification that the              
          requirements of any applicable law or administrative procedure              
          have been met.  Nestor v. Commissioner, 118 T.C. 162, 166 (2002).           
               In the instant case, the Appeals officer reviewed                      
          transcripts of petitioner’s account for 1994, 1997, 1998, and               
          1999, as well as other relevant items in the case file.  The                
          Appeals officer verified that all applicable laws and                       
          administrative procedures had been met and that petitioner                  
          received notice and demand for payment for the unpaid tax                   






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