Jonita Conner - Page 6

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          6330(c)(2)(A).  The taxpayer also may raise challenges to the               
          existence or amount of the underlying tax liability at a hearing            
          if the taxpayer did not receive a statutory notice of deficiency            
          with respect to the underlying tax liability or did not otherwise           
          have an opportunity to dispute that liability.  Sec.                        
          6330(c)(2)(B); Montgomery v. Commissioner, 122 T.C. 1 (2004).               
               This Court has jurisdiction under section 6330 to review the           
          Commissioner’s administrative determinations.  Sec. 6330(d);                
          Iannone v. Commissioner, 122 T.C. 287, 290 (2004).  Where, as               
          here, the validity of the underlying tax liability is not at                
          issue, we review the determination for abuse of discretion.  Sego           
          v. Commissioner, 114 T.C. 604, 610 (2000); Goza v. Commissioner,            
          114 T.C. 176, 182 (2000).  Whether an abuse of discretion has               
          occurred depends upon whether the exercise of discretion is                 
          without sound basis in fact or law.  See Freije v. Commissioner,            
          125 T.C. 14, 23 (2005).  The Commissioner’s refusal to consider             
          collection alternatives is not an abuse of discretion where the             
          taxpayer has failed to file all required tax returns or to                  
          provide complete financial information.  See Roman v.                       
          Commissioner, T.C. Memo. 2004-20; Rodriguez v. Commissioner, T.C.           
          Memo. 2003-153 (and cases cited therein).                                   
               Petitioner contends she sent the requested information to              
          respondent on November 28, 2005.  Petitioner testified that she             
          did not send the information by certified or registered mail,               






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