- 6 - be questioned, and we review respondent’s determination under an abuse of discretion standard. The main thrust of petitioner’s challenge concerns the computations in the deficiency proceeding under Rule 155. However, as noted, petitioner is not entitled to question the underlying tax liabilities because he already has been provided the opportunity to challenge his liabilities. See sec. 6330(c)(2)(B). In that regard, petitioner was provided with the opportunity to submit a computation under Rule 155, but failed to timely do so. Petitioner contends that Mr. Wall, his attorney, did not submit a Rule 155 computation. Petitioner’s contention with respect to his attorney’s failure does not change the limitation upon petitioner or the Court with respect to addressing the underlying merits of his 1993 or 1994 tax liability. See sec. 6330(c)(2)(B). With respect to petitioner’s second argument, concerning his attempted offer-in-compromise, our review of the Commissioner’s determination generally is limited to issues raised at the section 6330 hearing. Magana v. Commissioner, 118 T.C. 488, 493 (2002). Petitioner’s offer-in-compromise was submitted after the scheduled section 6330 hearing and the issuance of the final notice. Accordingly, the offer-in-compromise could not have been considered at the section 6330 hearing. There would, therefore,Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011