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denied because recording was not permitted, and we explained as
follows:
Now, the point that I want to make sure that you
understand here is that this hearing is being recorded,
and it will be recorded verbatim. So that any issues
that you wish to raise, you need to raise them here,
because you won’t get another chance to raise them
somewhere else unless I conclude at the end of this
trial that there are issues which must be ruled upon by
an appeals officer, and which are legitimate issues, so
that I can determine if that appeals officer abused
their discretion.
If there are no legitimate issues, then there is
nothing for me to determine that the appeals officer
has abused--that is, that there is no issue that the
appeals officer could have abused their discretion on,
and so there is no need to remand the case.
Petitioner proceeded to make a lengthy argument focusing
primarily on his contention that, in denying a recorded hearing
and in refusing to clarify the statutes and regulations used to
determine any taxable income, respondent violated the letter and
intent of the law. Petitioner asked that the determination be
vacated and that an award be issued under section 7433. However,
petitioner declined to be sworn in or to offer any other
testimony or evidence.
Following the proceedings, each party filed a posttrial
brief. Petitioner recapitulated his arguments made at trial and
prayed for a series of remedies, most of which are not within the
jurisdiction of this Court.
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Last modified: May 25, 2011