- 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