129 T.C. No. 19 UNITED STATES TAX COURT PETER P. BALTIC AND KAREN R. BALTIC, Petitioners v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No 2826-06L. Filed December 27, 2007. Bs received a notice of deficiency but filed no petition in this Court. R assessed the tax reported and then sent Bs CDP Notices that he had filed notices of federal tax lien and intended to collect the unpaid tax by levy. Bs requested a CDP hearing, at which they presented an offer-in-compromise based on doubt as to liability. R’s officer who conducted the hearing issued a notice of determination sustaining the filing of the lien and postponing the levy but refused to consider Bs’ proposed offer herself. Held: R committed no abuse of discretion in issuing the notice of determination, because section 6330(c) bars taxpayers who’ve received a notice of determination from challenging their underlying tax liability, and an offer-in-compromise based only on doubt as to liability is a challenge to that underlying liability.Page: 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: March 27, 2008