Robert L. Perkins - Page 1

                                   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 on                   

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Last modified: November 10, 2007