- 4 -
Commissioner, supra at 821; Jacklin v. Commissioner, supra at
344.
We further note that respondent objected to the admission of
four documents received at the Court hearing, on the grounds that
they were not part of the administrative record. Petitioner
credibly testified that all of these documents had been provided
to the IRS at some point (possibly before the section 6330
hearing) and that at least some of these documents were submitted
to the settlement officer as part of the section 6330 hearing.
Accordingly, the issue of what documents should be contained in
petitioner’s administrative record also is in dispute.
Material facts remain in dispute. Accordingly, summary
judgment is inappropriate at this juncture.
To reflect the foregoing,
An appropriate order will
be issued.
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Last modified: May 25, 2011