- 6 - “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.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011