Hailu Yohannes Awlachew - Page 11




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          supra at 610.  The Court reviews all other administrative                   
          determinations for abuse of discretion.  Id.                                
          I.  Petitioner’s Challenge to the Underlying Tax Liabilities                
               Section 6330(c)(2)(B) provides that a taxpayer may dispute             
          the existence or amount of his unpaid tax liability if he did not           
          receive a notice of deficiency or otherwise have an opportunity             
          to dispute such tax liability.  The “opportunity to dispute such            
          tax liability” includes a conference with the Appeals Office that           
          was offered either before or after the tax liability was                    
          assessed.  Sec. 301.6320-1(e)(3), Q&A-E2, Proced. & Admin. Regs.            
               Most of petitioner’s arguments are directed to collection              
          alternatives and do not raise challenges to the underlying tax              
          liabilities for 2000 and 2001.  However, during the                         
          administrative proceeding, petitioner inquired about the                    
          possibility of offsetting his unpaid liabilities with the AMT               
          that he had paid.  The record contains no evidence that the                 
          settlement officer specifically answered his inquiry.  In this              
          proceeding, petitioner has again raised the question of whether             
          he can reduce his unpaid tax liabilities by the amount of AMT he            
          paid.  Although his argument is very unclear, we interpret it as            
          an assertion that he is entitled to a credit under section 53.              
               Section 53 authorizes a taxpayer to claim a credit for net             
          minimum tax paid in prior years, adjusted for specified items.              
          The minimum tax credit allowable under section 53 is the excess             







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