- 6 - issues not otherwise raised in these assignments of error are deemed conceded. Id. In his underlying petition, petitioner made no such assignments of error with respect to respondent’s determination. The petition only contained statements that petitioner objected to the determination on the basis that the Federal tax system was both voluntary and inherently unfair. Accordingly, pursuant to Rule 331(b)(4), the Court holds that petitioner conceded all other issues relevant to the notice of determination. We finally consider whether respondent has verified, pursuant to section 6330(c)(1), that all of the requirements of applicable law or administrative procedure were satisfied with respect to the CDP action. The underlying record contains the declaration of Monty Luhmann (Mr. Luhmann), a settlement officer with respondent’s Office of Appeals, in which Mr. Luhmann attested to the underlying tax and penalty assessments made against petitioner for the years 1997, 1998, and 1999. Mr. Luhmann’s attestation was based upon his review of respondent’s transcripts generated by its Integrated Data Retrieval System. These transcripts contain petitioner’s name, Social Security number, the amounts assessed, and gross and taxable income. The Court has held that the use of records containing such information by an Appeals officer is not an abuse of discretion when used to verify an assessment. Kuglin v. Commissioner, T.C.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011