Shuang-Di Sun Bennett - Page 35

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          review of petitioner’s underlying tax liability, and there is no            
          reason to give further consideration to that issue.  Respondent’s           
          hearing officer obtained verification that any applicable law or            
          administrative procedure was met before making his determination            
          to proceed with collection.                                                 
               On the basis of the foregoing, we conclude that there was no           
          abuse of discretion by respondent’s hearing officer.  All the               
          requirements of section 6330 have been satisfied, and respondent            
          may proceed with his proposed collection action as to                       
          petitioner’s underlying tax liability, as determined by the                 
          Court.                                                                      
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing,                                              

                                                  An appropriate order and            
                                             decision will be entered.                


















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