- 7 - sufficient determination to make the related notice of deficiency valid. Palmer v IRS, 116 F.3d 1309, 1313-1314 (9th Cir. 1997). Because petitioner received a valid notice of deficiency relating to 1992 and 1993, he is precluded under section 6330(c)(2)(B) from now challenging his 1992 and 1993 Federal income tax liabilities. In the collection hearing, petitioner also contested the validity of the assessments. Petitioner’s arguments, however, were based upon frivolous arguments that have been uniformly rejected by this and other courts and do not merit discussion. Because petitioner did not present to respondent’s Appeals Office collection alternatives and only advanced frivolous reasons why the proposed levy is inappropriate, we conclude that respondent’s Appeals Office did not abuse its discretion in issuing the notice of determination sustaining respondent’s levy notice. For the reasons stated, we shall deny petitioner’s motion for summary judgment and grant respondent’s motion for summary judgment. To reflect the foregoing, An appropriate order and decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7
Last modified: May 25, 2011