- 9 - The only issue that petitioner appears to raise in the petition in this case is the underlying tax liability for peti- tioner’s taxable years 1995, 1996, 1997, 1999, and 2000. In the petition, petitioner alleges: I was under tremendous stress and medical conditions that did not allow me to function normally in the daily life. As soon as I became capable of living my normal life I addressed the issues that burdened me during that time. [Reproduced literally.] Respondent issued a notice of deficiency to petitioner with respect to his taxable years 1995, 1996, 1997, 1999, and 2000, but petitioner did not file a petition with the Court with respect to that notice. On the instant record, we find that petitioner may not challenge the existence or the amount of petitioner’s unpaid liabilities for 1995, 1996, 1997, 1999, and 2000. See sec. 6330(c)(2)(B); Sego v. Commissioner, 114 T.C. 604, 610-611 (2000); Goza v. Commissioner, 114 T.C. 176, 182-183 (2000). Where, as is the case here, the validity of the underlying tax liability is not properly placed at issue, the Court will review the determination of the Commissioner of Internal Revenue for abuse of discretion. Sego v. Commissioner, supra at 610; Goza v. Commissioner, supra at 182. Based upon our examination of the entire record before us, we find that respondent did not abuse respondent’s discretion in making the determinations in the notice of determination withPage: Previous 1 2 3 4 5 6 7 8 9 10 Next
Last modified: May 25, 2011