Chester E. Davis - Page 11




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          issuing the determination, not that he or she provide it to the             
          taxpayer.  Further, there is no legal requirement that the                  
          Appeals officer provide a taxpayer with copies of the delegations           
          of authority, assessment records, or other underlying documents             
          maintained by respondent with respect to a taxpayer’s account.              
          Nestor v. Commissioner, supra at 166.   Accordingly, the Appeals            
          officer in this case sufficiently verified the 2001 tax                     
          assessments and was not required to provide more.                           
          The 2001 Tax Liability                                                      
               A taxpayer may challenge the existence or amount of the                
          underlying tax, however, only if he did not receive any statutory           
          notice of deficiency for the tax liability or did not otherwise             
          have an opportunity to dispute the tax liability.  Sec.                     
          6330(c)(2)(B).  Where the validity of the underlying tax                    
          liability is properly in issue, the Court will review the matter            
          de novo.  Where the validity of the underlying tax is not                   
          properly in issue, however, the Court will review the                       
          Commissioner's administrative determination for abuse of                    
          discretion.  Sego v. Commissioner, 114 T.C. 604, 610 (2000); Goza           
          v. Commissioner, 114 T.C. at 181-182.                                       
               In this case petitioner was not entitled to contest the                
          underlying tax liability for 2001, the only year that this Court            
          has jurisdiction to consider.  Even if petitioner had been                  
          entitled to contest the underlying tax liability, other than                







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