- 11 - respect to petitioner’s 1999 return appear to be respondent’s good faith attempt to give petitioner the benefit of what appeared to be valid dependency exemptions. Respondent’s actions were not illegal or unconstitutional, and they cast no doubt on the validity of the notice of deficiency for 1999. We lack jurisdiction to consider petitioner’s contentions regarding his offer in compromise because our jurisdiction in this case is limited to redetermining petitioner’s correct tax liabilities for 1999 and 2000. To consider petitioner’s contentions concerning a conspiracy or vendetta against him, we would have to consider evidence of respondent’s conduct other than that stated in the notices of deficiency. The notices directly pertain to petitioner and were issued after an audit. Petitioner has not alleged any conduct by respondent sufficient to cause us to look behind the statutory notices of deficiency under Greenberg’s Express, Inc. v. Commissioner, 62 T.C. 324 (1974). We are satisfied that petitioner raises no issue warranting that we look behind the statutory notices of deficiency. Petitioner contends that Bennett v. Commissioner, T.C. Memo. 1997-505, created an exception to this rule when there is substantial evidence of unconstitutional conduct by the Commissioner.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011