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respect to which the liabilities at issue in this case were
assessed.
G. Underlying Tax Liabilities
Petitioners also raise several issues that attack the
validity of the underlying tax liabilities for 1996 and 1997.
Since petitioners received a notice of deficiency with
respect to those years and did not petition this Court regarding
that notice, they are now precluded from disputing the existence
or amount of the underlying tax liabilities. Sec. 6330(c)(2)(B);
Nestor v. Commissioner, supra.
H. Conclusion
Petitioners have not raised any spousal defenses, challenges
to the appropriateness of the collection action, or collection
alternatives. We have considered every contention raised by
petitioners, and conclude that there are no genuine issues of
material fact, and that respondent is entitled to judgment as a
matter of law. We shall therefore grant respondent’s motion for
summary judgment. To reflect the foregoing,
An appropriate order and
decision will be entered.
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Last modified: May 25, 2011