Chi Wai - Page 10

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                    to the extent such use would result in the                        
                    taxpayer not having adequate means to provide                     
                    for basic living expenses.                                        
               Regulations adopted pursuant to section 7122 set forth three           
          grounds for the compromise of a liability:  (1) Doubt as to                 
          liability; (2) doubt as to collectibility; or (3) promotion of              
          effective tax administration.  Speltz v. Commissioner, supra at             
          172; sec. 301.7122-1, Proced. & Admin. Regs.  In her petition,              
          petitioner asserts that there was an abuse of discretion as to              
          all three grounds, although she pursued only promotion of ETA at            
          the CDP hearing.                                                            
               Generally, we may consider only those issues that the                  
          taxpayer raised during a section 6330 hearing.  Sapp v.                     
          Commissioner, T.C. Memo. 2006-104; sec. 301.6330-1(f)(2), Q&A-F5,           
          Proced. & Admin. Regs.; see also Magana v. Commissioner, 118 T.C.           
          488, 493 (2002).  Respondent asserts that petitioner did not                
          raise the issue of doubt as to liability at her Appeals hearing,            
          which petitioner disputes.  In any event, petitioner has failed             
          to aver facts or legal argument sufficient to show error in                 
          respondent’s assessment.  See Poindexter v. Commissioner, 122               
          T.C. 280, 284-285 (2004), affd. 132 Fed. Appx. 919 (2d Cir.                 
          2005).  Petitioner has not argued that the computation of the AMT           
          on her year 2000 return is incorrect, but she argues instead that           









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