Crevenne C. and Barbara A. Carrillo - Page 21

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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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