- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011