Norman P. Schneller - Page 4

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          administrative determination for an abuse of discretion.  Sego v.           
          Commissioner, 114 T.C. 604, 610 (2000); Goza v. Commissioner, 114           
          TC 176, 181-182 (2000).                                                     
               Although petitioner received a statutory notice of                     
          deficiency for the taxable year 2001, he did not avail himself of           
          the opportunity to file a petition for redetermination of the               
          deficiency with this Court pursuant to section 6213(a).                     
          Consistent with section 6330(c)(2)(B), petitioner therefore was             
          precluded from contesting his liability for the underlying taxes            
          before the Appeals Office.  Goza v. Commissioner, supra at 182-             
          183.  Therefore, the validity of petitioner's underlying tax                
          liability is not properly at issue in this proceeding.  Id. at              
          183.                                                                        
               Nevertheless, petitioner continues to assert frivolous                 
          claims.  See, e.g., Pond v. Commissioner, T.C. Memo. 2005-255               
          (rejecting taxpayer’s argument that exemption amount is not                 
          defined by statute); Saxon v. Commissioner, T.C. Memo. 2006-52              
          (taxpayer’s contention that OMB control No. 1545-0074, on the               
          Form 1040 is invalid and does not comply with the requirements of           
          the PRA is groundless (citing James v. United States, 970 F.2d              
          750, 753 n.6 (10th Cir. 1992); United States v. Neff, 954 F.2d              
          698, 699 (11th Cir. 1992)).  Petitioner does not challenge the              
          appropriateness nor the intended method of collection.  Nor does            
          petitioner offer any alternative means of collection or raise any           






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