- 8 - OPINION I. Petitioner’s Contentions In his petition, petitioner raises numerous technical and procedural complaints about respondent’s determination to proceed with collection action. Petitioner filed no posttrial brief. In his pretrial memorandum, petitioner distilled his complaints into these three issues: (1) Whether the Appeals Office failed to offer petitioner the hearing that he requested pursuant to section 6330(b)(1); (2) whether this Court may redetermine his 1992 underlying income tax liability; and (3) whether the notices of determination are invalid because they contain some incorrect references to petitioner’s 1998 tax year and account.7 II. Whether the Appeals Office Failed To Offer Petitioner a Hearing If a taxpayer fails to pay any Federal tax liability within 10 days of notice and demand, the Secretary is authorized to collect the tax by levy on the taxpayer's property. Sec. 6331(a). At least 30 days before taking collection action, the Secretary must provide the taxpayer with a final notice of intent to levy that describes, among other things, the availability of administrative appeal. Sec. 6331(d). 7 We have carefully considered all issues raised in the petition. We construe most of them as falling within the ambit of the three issues identified above, and we address them in that context. The other issues raised in the petition are without merit, moot, or irrelevant; in any event, we deem petitioner to have abandoned such other issues.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