- 15 - declined to grant respondent’s motion for summary judgment. The record as it then existed did not foreclose the possibility that petitioner might have raised valid arguments had a hearing been held. Accordingly, we provided petitioner an opportunity before the Court at the trial session in Phoenix to identify any legitimate issues he wished to raise that could warrant further consideration of the merits of his case by the Appeals Office or this Court. At trial, the comments of petitioner and his wife focused almost exclusively on petitioner’s assertion that he did not receive the notices of deficiency and on corollary matters regarding his address. However, as will be explained in greater detail below, petitioner failed to raise any legitimate substantive issues requiring or justifying additional review under the framework of section 6330. The record therefore does not indicate that any purpose would be served by remand or additional proceedings. The Court concludes that all pertinent issues relating to the propriety of the collection determination can be decided through review of the materials before it. 2. Review of Underlying Liabilities The evidentiary record establishes that statutory notices determining deficiencies with respect to the 1993, 1994, 1995, 1996, and 1997 taxable years were issued to petitioner. Respondent’s records indicate that the notices were returned asPage: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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