Rudolph Harris, Sr., and Verline Harris - Page 9

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               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.                                                                  




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