Kevin M. Moore - Page 7




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          Commissioner, 114 T.C. 604, 609 (2000); Goza v. Commissioner, 114           
          T.C. 176, 180 (2000).  If a taxpayer received a statutory notice            
          of deficiency for the years in issue or otherwise had the                   
          opportunity to dispute the underlying tax liability, the taxpayer           
          is precluded from challenging the existence or amount of the                
          underlying tax liability.  Sec. 6330(c)(2)(B); Sego v.                      
          Commissioner, supra at 610-611; Goza v. Commissioner, supra at              
          182-183.                                                                    
               Petitioner received notices of deficiency for 1997, 1999,              
          2000, and 2001.  Accordingly, he cannot challenge his underlying            
          liabilities for those years.  See sec. 6330(c)(2)(B); Sego v.               
          Commissioner, supra at 610-611; Goza v. Commissioner, supra at              
          182-183.                                                                    
               At trial, the Court gave petitioner several opportunities to           
          present evidence regarding his underlying liabilities for 1998              
          and 2002.  The Court asked petitioner several times whether he              
          wanted to address his deficiencies or underlying liabilities.               
          When asked by the Court whether he had anything to say about his            
          deficiencies or underlying liabilities, petitioner answered “No.”           
          Accordingly, we review respondent’s determination for 1997, 1998,           
          1999, 2000, 2001, and 2002 for an abuse of discretion.  See Sego            
          v. Commissioner, supra at 610.                                              
               Settlement Officer Feist conducted a thorough review of the            
          financial information that petitioner provided to him.  Upon the            







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