Richard Fransen - Page 13




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          2000, 2001, and 2002.                                                       
               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, 114 T.C. 604, 610           
          (2000); Goza v. Commissioner, 114 T.C. 176, 181-182 (2000).                 
               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 regard-            
          ing the notice of tax lien with respect to petitioner’s taxable             
          years 2000, 2001, and 2002.                                                 
               We have considered all of the contentions and arguments of             
          the parties that are not discussed herein, and we find them to be           
          without merit, irrelevant, and/or moot.                                     
               On the record before us, we shall grant respondent’s motion.           
               To reflect the foregoing,                                              

                                             An order granting respondent’s           
                                        motion and decision for respondent            
                                        will be entered.                              






               5(...continued)                                                        
          that petitioners reported due on their tax return along with                
          statutory interest and penalties.”  Id. at 8.                               





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