Estate of Nancy Sblendorio, Deceased, Michael F. Poppo, Executor - Page 7

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          & Admin. Regs.; see Lewis v. Commissioner, 128 T.C. __ (2007)               
          (finding section 301.6330-1(e)(3), Q&A-E2, Proced. & Admin.                 
          Regs., to be a reasonable interpretation of section                         
               Upon notice of the additions to tax, Mr. Poppo filed a                 
          request for abatement with respondent’s Cincinnati Service                  
          Center.  Mr. Poppo submitted correspondence presenting                      
          information in support of his request and argued that the                   
          additions to tax should be abated for reasonable cause.  The                
          request for abatement was denied, and Mr. Poppo then filed an               
          appeal with respondent’s Appeals Office.  Mr. Poppo again                   
          submitted correspondence and participated in multiple telephone             
          conversations with the Appeals officer, presenting information              
          and arguments in support of his request for abatement of the                
          additions to tax.  The Appeals officer then sustained the                   
          assessment of the additions to tax.  Thus, we find Mr. Poppo was            
          afforded a conference with Appeals in which he had the                      
          opportunity to dispute the underlying liability for additions to            

          consideration of an underlying tax liability in a collection                
          review proceeding.  We reserve judgment on whether such an offer            
          would preclude subsequent consideration of an underlying                    
          liability in a collection review proceeding (and if so, what                
          information would have to be included in the offer).                        

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