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“compensation” were erroneously reported as wages.
Because petitioner received a statutory notice of deficiency
for the year for which collection is at issue here, he may not
raise his frivolous challenges to the existence or amount of the
underlying tax liability. Sec. 6330(c)(2)(B). Petitioner did
not raise any permitted argument with respect to spousal
defenses, challenges to the appropriateness of the Commissioner’s
intended collection action, or alternative means of collection.
Conclusion
Respondent’s determination to proceed with collection action
was not an abuse of his discretion.
Reviewed and adopted as the report of the Small Tax Case
Division.
To reflect the foregoing.
Decision will be entered
for respondent.
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Last modified: May 25, 2011