Benedict John Casey - Page 14

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          procedure have been met”.  See, e.g., Yacksyzn v. Commissioner,             
          T.C. Memo. 2002-99.                                                         
               In the attachment to each notice of determination, Appeals             
          Officer Cody states:  “I have had no prior involvement with this            
          taxpayer concerning the 1998 tax period before this CDP case.”              
          On the basis of this statement, which misstates the tax period in           
          question, petitioner alleges that respondent failed to show that            
          the Appeals officer was “impartial” with respect to this                    
          collection proceeding as required by section 6330(b)(3).  As                
          previously indicated, we attach little significance to the                  
          typographical error regarding the tax period in question.  For              
          purposes of section 6330(b)(3), an “impartial” officer is one               
          “who has had no prior involvement with respect to the unpaid tax            
          specified in subsection (a)(3)(A) before the first hearing under            
          this section or section 6320.”  See Perez v. Commissioner, T.C.             
          Memo. 2002-274.  Petitioner has presented no evidence that                  
          Appeals Officer Cody was previously involved in his case.  We               
          conclude that the section 6330(b)(3) impartiality requirement was           
          satisfied in this case.                                                     
          V.   Conclusion                                                             
               Petitioner has not made a valid challenge to the                       
          appropriateness of the proposed collection action or offered any            
          collection alternatives.  The Appeals officer did not act in an             
          arbitrary or capricious way, or in an unlawful or unreasonable              






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