-4- underlying tax liability de novo. See Sego v. Commissioner, 114 T.C. 604, 610 (2000); Hoffman v. Commissioner, 119 T.C. 140, 144-145 (2002). Petitioner raises no valid legal arguments. She argues, in both her request for a hearing and in her petition to this Court, that she does not owe any tax for 1996. This she may not do. Petitioner, having received a notice of deficiency and having forgone the opportunity to challenge her underlying liability in her prior case, is barred from doing so in this case. See sec. 6330(c)(2)(B); Ginalski v. Commissioner, T.C. Memo. 2004-104. C. Conclusion We shall grant respondent’s motion for summary judgment. To reflect the foregoing, An appropriate order and decision will be entered for respondent.Page: Previous 1 2 3 4
Last modified: May 25, 2011