- 19 -
judgment. The record as it then existed did not foreclose the
possibility that petitioners might have raised valid arguments
had a hearing been held. Accordingly, we provided petitioners an
opportunity before the Court at the trial session in Las Vegas to
identify any legitimate issues they wished to raise that could
warrant further consideration of the merits of their case by the
Appeals Office or this Court. Petitioners, however, merely
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
petitioners 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
As regards 1997 and 1998, petitioners, in asserting that
they are not bound to pay Federal income taxes, are essentially
seeking to challenge even the underlying liabilities they
reported on their original returns. No notice of deficiency was
issued to petitioners for either 1997 or 1998, but petitioners
Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 NextLast modified: May 25, 2011