Thomasita Taylor - Page 15

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               Hence, despite repeated warnings and opportunities, the only           
          contentions advanced by petitioner are, as will be further                  
          discussed below, of a nature previously rejected by this and                
          other courts.  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 on respondent’s renewed motion            
          for summary judgment.                                                       
                    2.  Review of Underlying Liabilities                              
               The evidentiary record establishes that a statutory notice             
          determining deficiencies with respect to the 1993, 1994, 1995,              
          and 1996 taxable years was issued to petitioner.  Copies of the             
          notice itself and a certified mail list clearly reflect that the            
          notice was sent to petitioner’s last known, and current, address.           
          To the extent that petitioner made allegations to the contrary in           
          her Form 12153, such contentions are refuted by the evidence and,           
          in any event, were not pursued before the Court.  Accordingly,              
          because petitioner received a valid notice of deficiency and did            
          not timely petition for redetermination, she is precluded under             
          section 6330(c)(2)(B) from disputing her underlying tax                     
          liabilities in this proceeding.                                             









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