- 10 - 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 thatPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011