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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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