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taxpayer may raise any ‘relevant’ issue at the collection
hearing; it does not say that the taxpayer may raise ‘any’ issue.
Petitioner raised only groundless and frivolous issues, not
relevant issues.” Hathaway v. Commissioner, T.C. Memo. 2004-15.
Petitioners have challenged the “existence” of their
underlying tax liabilities only through generalized contentions
that no statute imposes or requires them to pay income taxes.
They have at no time alleged that they did not in fact receive
the funds on which the tax liabilities for 1997 and 1998 are
based. Thus, even if petitioners were permitted to challenge
their underlying liabilities in this proceeding, they have raised
no genuine, relevant issue as to the amount of such liabilities
for 1997 or 1998.
With respect to 1999 and 2000, petitioners were issued
statutory notices of deficiency and did not file petitions
challenging those notices in this Court. Furthermore,
communications from petitioners expressly reference the notices
of deficiency, making clear that these documents were received.
To the extent that petitioners have argued that they should
nonetheless be entitled to challenge their underlying liabilities
on grounds that the notices were invalid, due to a lack of a
delegation of authority from the Secretary to the individual in
Ogden, Utah, signing the notices, this contention is without
merit.
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