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
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Last modified: March 27, 2008