Wendell Ray Holloway - Page 10




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          require the IRS to collect unpaid amounts from her rather than              
          from him.  Cf. Baranowicz v. Commissioner, 432 F.3d 972 (9th Cir.           
          2005); Kovitch v. Commissioner, 128 T.C. 108 (2007); Maier v.               
          Commissioner, 119 T.C. 267 (2002), affd. 360 F.3d 361 (2d Cir.              
          2004); Miller v. Commissioner, 115 T.C. 582, 586-588 (2000),                
          affd. 21 Fed. Appx. 160 (4th Cir. 2001).                                    
               Petitioner contends that the failure to record the hearing             
          and the failure to have certain documents in the form of                    
          admissible evidence make the determination “null, void, and                 
          unenforceable”; that the assignment of his hearing to a                     
          Settlement Officer rather than an Appeals Officer and the                   
          issuance of the notice of determination signed by an Appeals Team           
          Manager were denials of due process and render the notice                   
          “unenforceable”; and that certain IRS employees were not                    
          competent to take the steps reflected in the administrative                 
          record.  Although petitioner had the option, under section 7521,            
          to request in advance that the hearing be recorded, he has                  
          stipulated that he did not make such a request.  Despite his                
          rhetoric, petitioner has not shown any requirement of law that              
          was not followed by the persons involved.  He has not                       
          acknowledged or distinguished law contrary to his contentions.              
          See, e.g., Living Care Alternatives of Utica, Inc. v. United                
          States, 411 F.3d 621, 624 (6th Cir. 2005); Cox v. Commissioner,             








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