129 T.C. No. 7 UNITED STATES TAX COURT ROBERT L. PERKINS, Petitioner v. COMMISSIONER OF INTERNAL REVENUE, Respondent Docket No. 21997-04L. Filed September 13, 2007. P timely filed his Federal income tax return for 2000 but failed to pay fully the amount reported as due. R increased the Federal income tax liability reported by P on his 2000 return and assessed the increase pursuant to sec. 6213(b)(1), I.R.C. After expiration of the period in which to request abatement of the increased assessment under sec. 6213(b)(2), I.R.C., P appealed the increase in a letter that was forwarded to R's Office of Appeals. While consideration by Appeals was pending, R issued P a notice of intent to levy to collect the outstanding liability for 2000. P timely requested a hearing pursuant to sec. 6330(a)(3)(B), I.R.C. Before a hearing was scheduled, R's Office of Appeals responded to P's appeal of the increase in his 2000 liability, treating it as a claim for abatement and denying it. Thereafter, the Appeals employee conducting P's hearing under sec. 6330, I.R.C., did not allow P to challenge the underlying tax liability onPage: 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007