- 7 - & 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).Page: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: November 10, 2007