- 7 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011