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warrant further consideration of the merits of his case by the
Appeals Office or this Court. Petitioner, 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
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
With respect to 1999, a statutory notice of deficiency was
issued to petitioner, and he has at no time alleged that he did
not receive the notice. He did not timely petition this Court
for redetermination when he had the opportunity to do so.
Accordingly, petitioner is precluded under section 6330(c)(2)(B)
from disputing his underlying liability for 1999 in this
proceeding.
With respect to 1998, because the assessments were based on
petitioner’s filed return, no notice of deficiency was issued.
However, to the extent that petitioner might be entitled to
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