- 14 -
arguments. Accordingly, we provided petitioner an opportunity
before the Court at the trial session in Las Vegas to identify
any legitimate issues he wished to raise that could warrant
further consideration of the merits of his case by the Appeals
Office or this Court. Petitioner, however, merely continued to
focus on the denial of a hearing and offered no substantive
issues of merit.
Hence, despite repeated warnings and opportunities, the only
contentions other than the face-to-face hearing 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.
2. Review of Underlying Liabilities
Statutory notices of deficiency for 1993 and 1994 were
issued to petitioner. However, the parties stipulated that
petitioner did not receive those notices, and respondent has
agreed that petitioner was entitled to challenge his underlying
liability under section 6330(c)(2)(B). Yet petitioner has at no
time offered even a scintilla of evidence that would show error
in respondent’s determinations. His only contentions bearing on
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