Raymond Gori - Page 7

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          T.C. 1, 8-9 (2004).  Because the tax liability due is one                   
          petitioner reported due on his return, he did not receive a                 
          notice of deficiency or otherwise have an opportunity to dispute            
          the 1998 tax liability.                                                     
               For the validity of the 1998 underlying tax liability to be            
          properly at issue, petitioner must comply with Rule 331.  His               
          pleading must contain a sufficient specificity of facts so that             
          the Court can conduct a meaningful hearing to determine whether             
          respondent can proceed with collection.  Petitioner has failed to           
          comply with Rule 331.  He has not identified items of income,               
          deduction, or credit, or the computations that are incorrect.               
          Poindexter v. Commissioner, 122 T.C. 280, 285 (2004).                       
               Petitioner was told repeatedly by the Appeals officer that             
          the arguments raised in his request for a hearing were considered           
          irrelevant and frivolous by the Internal Revenue Service and this           
          Court.  Petitioner insisted in pursuing these arguments and                 
          failed to assert any other issues, such as the ones listed in               
          section 6330(c)(2)(A).  In particular, petitioner never made an             
          offer of an alternative means of collection during the Appeals              
          process.  We therefore find that petitioner has raised no issue             
          that would warrant a remand to the Appeals Office for another               
          hearing.  See Lunsford v. Commissioner, 117 T.C. 183, 189 (2001);           
          Kemper v. Commissioner, T.C. Memo. 2003-195.                                







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