- 2 - 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 forPage: Previous 1 2 3 4 5 6 7 8 9 10 11 NextLast modified: November 10, 2007