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that he should have been permitted to contest the underlying tax
liabilities at the hearing. Petitioner asserts that respondent’s
delay in processing his hearing request resulted in additional
interest accruing on the tax liabilities.
Respondent asserts that petitioner’s case is moot because
the underlying tax was paid, the tax liabilities, including
interest, and additions to tax have been paid, and the notices of
Federal tax liens for all years in question have been released.
Furthermore, respondent asserts that petitioner cannot dispute
the 1995 and the 1996 tax liabilities because petitioner had a
prior opportunity to dispute the tax and waived his right to
dispute the underlying liabilities by his agreement to the
assessment of the tax for each year. As to all tax years in
issue, respondent asserts that petitioner is not entitled to
abatement of interest and additions to tax.
Discussion
Mootness
This Court has jurisdiction under section 6330 to review the
Commissioner’s administrative determinations. Sec. 6330(d); see
Iannone v. Commissioner, 122 T.C. 287, 290 (2004). We have also
stated that our review is generally limited to whether the
4(...continued)
tax returns was also assessed.
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