Peter P. Baltic and Karen R. Baltic - Page 1


          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                

Page:  1  2  3  4  5  6  7  8  9  10  11  Next 

Last modified: March 27, 2008