Paul Thomas Demos - Page 8

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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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