- 6 - Petitioner raises two issues. First, he disagrees with the amount assessed. Second, he wants to make installment payments. Respondent argues that petitioner is prohibited from challenging the underlying liability because petitioner did not raise it at the section 6330 hearing, and this Court cannot determine whether respondent abused his discretion as to a matter not raised at the section 6330 hearing. We need not address whether petitioner raised the issue of his underlying liability or whether he is permitted to challenge it. Petitioner alleges no facts in the petition or any other pleadings that would show the assessed amounts are in error. See Rule 331(b)(5); Grant Creek Water Works, Ltd. v. Commissioner, supra; Casanova Co. v. Commissioner, supra. In addition, petitioner failed to respond to respondent’s motion. Respondent also argues that petitioner had the opportunity to pay under an installment plan but failed to comply with the conditions of entering into that agreement. Again, we need not address petitioner’s compliance with the terms of the proposed installment agreement. Petitioner did not respond to respondent’s motion or allege facts that would indicate it was an abuse of discretion for respondent to refuse to accept the proposed installment agreement.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011