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entitled to challenge the underlying tax liability. As such, it
is unnecessary to decide the remaining issue of whether
respondent abused his discretion by denying petitioner’s request
to consider the underlying merits of the 1995 tax liability. In
accordance with the parties’ agreement, this case will be
remanded to respondent’s Appeals Office to conduct a hearing in
accordance with section 6330.
To reflect the foregoing,
An appropriate order will
be issued.
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Last modified: May 25, 2011