- 9 -
The officer or employee of Appeals conducting a section 6330
hearing cannot turn a blind eye to or ignore relevant documents
in the Commissioner’s possession--especially when those documents
are specifically mentioned in other documents the officer or
employee of Appeals reviews or the officer or employee of Appeals
knows the documents exist. Upon the basis of the foregoing, we
conclude that the determination for the years in issue was an
abuse of discretion.6
To reflect the foregoing,
Decision will be entered
for petitioners.
6 Additionally, respondent conceded at trial and on brief
that Mr. and Mrs. Harris’s 1995 tax liabilities have been fully
satisfied.
Page: Previous 1 2 3 4 5 6 7 8 9
Last modified: May 25, 2011