Richard Mark Hansen - Page 9

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          intended collection activities, including spousal defenses,                 
          challenges to the appropriateness of the Commissioner’s intended            
          collection action, and alternative means of collection.  Secs.              
          6320(b), (c); 6330(c); see Sego v. Commissioner, 114 T.C. 604,              
          609 (2000); Goza v. Commissioner, 114 T.C. 176, 180 (2000).                 
               The taxpayer may raise challenges “to the existence or                 
          amount of the underlying tax liability”, however, only if he “did           
          not receive any statutory notice of deficiency for such tax                 
          liability or did not otherwise have an opportunity to dispute               
          such tax liability.”  Sec. 6330(c)(2)(B).                                   
               Petitioner did not receive notices of deficiency for 1997,             
          1998, or 2000.  Therefore, pursuant to sections 6320(c) and                 
          6330(c)(2)(B), petitioner was entitled to challenge the existence           
          or amount of the underlying tax liabilities for 1997, 1998, and             
          2000 at his Appeals Office hearing.  See Hoffman v. Commissioner,           
          119 T.C. 140, 145 (2002).  If the validity of those underlying              
          tax liabilities is properly at issue, the Court reviews the                 
          matter de novo.  Poindexter v. Commissioner, 122 T.C. 280, 284              
          (2004); Sego v. Commissioner, supra at 610.                                 
               Respondent assessed the tax shown on the tax returns                   
          petitioner submitted for 1997, 1998, and 2000.  Petitioner                  
          testified that he does not disagree with the amounts of tax                 
          respondent assessed for 1998 and 2000.  He does, however, dispute           
          the tax liability for 1997 and the penalties and interest                   






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