John Alfred Laszloffy - Page 7

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          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.                              








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