- 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.Page: Previous 1 2 3 4
Last modified: May 25, 2011