-12- As already noted, the only issue raised by petitioner at the Appeals hearing was that the Philadelphia Service Center had transposed numbers from the Tax Court decision documents and refused to abate the incorrect amounts. The Appeals officer determined that the tax, including penalties, reflected in the Tax Court decision documents had been correctly assessed, but that petitioner had not been credited with withholding tax for 1989, 1990, and 1992. Accordingly, the Appeals officer made three adjustment documents for crediting petitioner with the withholding taxes. Because petitioner in his petition persisted in maintaining that the IRS had made excessive and wrongful assessments, the Court, as already discussed, directed respondent, among other things, to explain how the liability for each year was computed, and to demonstrate the allowance of the 1989, 1990, and 1992 withholdings, which were not taken into account in respondent’s Levy Notice, dated March 22, 2004. Respondent’s notice of determination, issued after the Levy Notice, properly reflects the allowance of the withholding credits. In petitioner’s “Opposition” to Respondent’s Supplement, he makes no attempt whatsoever to demonstrate why he believes respondent transposed decision document numbers, or why respondent’s assessments are incorrect. Instead he persists inPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011