- 15 - See, e.g., Willoughby v. Commissioner, supra; 1 Restatement, Agency 2d, secs. 112 comment C, 165 (1958). Accordingly, the waivers are valid, and the assessment of the tax was proper. Under the circumstances, petitioner is deemed to have had a prior opportunity to dispute his liabilities for 1995, 1996, and 1997 within the meaning of section 6330(c)(2)(B). Consequently, petitioner is not entitled to challenge the existence or amount of his 1995, 1996, and 1997 tax liabilities during the collection review process. See Zapara v. Commissioner, 124 T.C. at 228; Aguirre v. Commissioner, 117 T.C. at 327. To reflect the foregoing, An order granting respondent’s motion for partial summary judgment will be issued.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15
Last modified: May 25, 2011