- 8 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011