- 21 - 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.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011