James E. Anderson and Cheryl J. Latos - Page 25




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          v. Commissioner, supra, we reject Ms. Latos’ arguments here with            
          respect to Ms. Latos’ unpaid 1998 liability.18                              
               In Anderson v. Commissioner, supra, the Court further held             
          that respondent’s Appeals officer complied with the verification            
          requirements of section 6330(c)(1) and that respondent did not              
          abuse respondent’s discretion in making the determinations at               
          issue in that case.  For the reasons stated in Anderson v.                  
          Commissioner, supra, we find that the settlement officer involved           
          in each of the instant cases complied with the verification                 
          requirements of section 6330(c)(1) and that respondent did not              
          abuse respondent’s discretion in making the respective determina-           
          tions over which we have jurisdiction19 in the 1995 through 1997            
          notice of determination and the 1998 notice of determination.20             


               18See also discussion supra note 17 addressing Ms. Latos’              
          misplaced reliance on United States v. Galletti, supra.                     
               19See supra note 13.                                                   
               20We reject as baseless Ms. Latos’ argument that the settle-           
          ment officer involved in each of the instant cases did not comply           
          with the verification requirements of sec. 6330(c)(1) because               
          such settlement officer did not “verify that all applicable laws            
          and procedures for the collection of employment taxes have been             
          met”.  (Emphasis added.)  The instant cases involve the collec-             
          tion of Ms. Latos’ unpaid self-employment tax liability for her             
          taxable year 1995 and her unpaid income tax liability for each of           
          her taxable years 1996, 1997, and 1998.  These cases do not                 
          involve the collection of employment tax for any of those years.            
          We note that although the self-employment tax is collected                  
          together with the income tax, it is not part of the income tax              
          itself.  Chatterji v. Commissioner, 54 T.C. at 1404.  As we                 
          indicated in Chatterji, “The self-employment tax imposed is ‘an             
          additional tax on the income derived by the self-employed * * *             
                                                             (continued...)           





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