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