- 7 - Each attachment indicates that the only issue raised by petitioner was the disallowance of his claimed mileage expenses and states in pertinent part: The only issue raised by the taxpayer is the fact that his mileage was not allowed * * * Since taxpayer was issued a Statutory Notice of Deficiency and did not petition Tax Court, this issue cannot be considered in connection to the CDP hearing. Taxpayer is not entitled to judicial review of the items in the Statutory Notice per IRC sec. 6330(c)(2)(B). However, I offered to review his records and consider his request for adjustment as an audit reconsideration, apart from the CDP [collection due process] hearing. Taxpayer never responded to my letters or telephone calls. * * * * * * * Taxpayer indicated in his request for a CDP hearing that he didn’t agree with the balance due because the agent didn’t allow him business miles. I offered taxpayer an audit reconsideration, apart from the CDP hearing, but taxpayer did not call or make the schedule[d] conference. His “mileage records” do not support an adjustment without further explanation and clarification. It appears taxpayer has a history of dropping the ball – making some contact – then not responding. This happened during the examination, with collection, and now in appeals. The levy balances the need for the efficient collection of taxes with the legitimate concern of Benedict John Casey that any collection action be no more intrusive than necessary, because he has failed to cooperate in proving the liability is incorrect and failed to offer any collection alternative.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011