James G. Gilligan - Page 9

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          in response to these notices of deficiency.  Accordingly,                   
          petitioner cannot contest the underlying deficiencies for 1994              
          and 1996.  Sec. 6330(c)(2)(B); Sego v. Commissioner, supra; Goza            
          v. Commissioner, supra at 182-183.  Claims that the limitation              
          period for assessment has expired are challenges to the                     
          underlying tax liability.  Boyd v. Commissioner, 117 T.C. 127,              
          130 (2001).  Additionally, the assessments were timely made.                
          Therefore, petitioner cannot raise these claims in this                     
          proceeding.                                                                 
               Where the validity of the underlying tax liability is not              
          properly in issue, we review the Commissioner’s determination for           
          an abuse of discretion.  Sego v. Commissioner, supra at 610.                
               Petitioner appears to argue that the verification                      
          requirement of section 6330 has not been met.  Section 6330(c)(1)           
          does not require the Commissioner to rely on a particular                   
          document to satisfy the verification requirement imposed therein.           
          E.g., Schnitzler v. Commissioner, T.C. Memo. 2002-159 (citing               
          five other cases to support this principle).  We have repeatedly            
          held that the Commissioner may rely on Forms 4340, Certificate of           
          Assessments, Payments, and Other Specified Matters, or                      
          transcripts of account to satisfy the verification requirement of           
          section 6330(c)(1).  Hromiko v. Commissioner, T.C. Memo. 2003-              
          107; Schnitzler v. Commissioner, supra; Kaeckell v. Commissioner,           
          T.C. Memo. 2002-114; Obersteller v. Commissioner, T.C. Memo.                






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