- 14 - warrant further consideration of the merits of his case by the Appeals Office or this Court. Petitioner, however, continued to focus on the denial of a recorded hearing and offered no substantive issues of merit. Hence, despite repeated warnings and opportunities, the only contentions other than the recorded hearing advanced by petitioner are, as will be further discussed below, of a nature previously rejected by this and other courts. The record therefore does not indicate that any purpose would be served by remand or additional proceedings. The Court concludes that all pertinent issues relating to the propriety of the collection determination can be decided through review of the materials before it. 2. Review of Underlying Liabilities Statutory notices of deficiency for 1998 and 1999 were issued to petitioner by certified mail. Furthermore, statements in the memorandum of law filed in support of petitioner’s response to respondent’s earlier motion for summary judgment make clear that he received the notices, despite assertions in various other documents that might suggest the contrary. In addition, the following colloquy on this subject took place at trial: THE COURT: All right. I have one question, Mr. Call. The order that I previously entered in your case denying the motion for summary judgment noted that the service had issued statutory notices of deficiencies to you for both the years of ’98 and ’99.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
Last modified: May 25, 2011