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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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