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otherwise indicated, all subsequent section references are to the
Internal Revenue Code as amended, and all Rule references are to
the Tax Court Rules of Practice and Procedure.
This case arises from a petition for judicial review filed
in response to a Notice of Determination Concerning Collection
Action(s) Under Section 6320 and/or 6330 (notice of
determination). The issues for decision are: (1) Whether
petitioner may challenge his underlying tax liabilities; (2) if
he may, whether remand to Appeals is necessary; and (3) if remand
is not necessary, whether respondent’s rejection of petitioner’s
offer-in-compromise constitutes an abuse of discretion.
Background
This case was submitted fully stipulated pursuant to Rule
122, and the facts as stipulated are so found. The stipulations
of the parties, with accompanying exhibits, are incorporated
herein by this reference. At the time he filed the petition,
petitioner resided in Linden, New Jersey.
Petitioner earned nonemployee compensation from L&P Trucking
in the amounts of $22,815 for 1987 and $20,830 for 1988, which
amounts were reported on Forms 1099-MISC, Miscellaneous Income.
In 1988 petitioner also received $2,341 in wages reported on Form
W-2, Wage and Tax Statement (Form W-2), from The Newark Group and
wages reported on Form W-2 in the amount of $45 from Beacon Hill
Club. However, petitioner failed to file income tax returns for
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Last modified: November 10, 2007