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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
6330(c)(2)(B)).
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
tax.
3(...continued)
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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Last modified: November 10, 2007