Robert L. Perkins - Page 19




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          respect to the liability at issue.  Assuming that petitioner                
          would have presented this issue if the Appeals employee had                 
          permitted challenges to the underlying liability, the contention            
          is groundless.  Generally, the amount of any tax imposed by the             
          Internal Revenue Code must be assessed within 3 years after the             
          return is filed.  Sec. 6501(a).  The liabilities at issue were              
          assessed in 2001, well within the 3 years after the filing of the           
          2000 return on April 16, 2001.  The 10-year period of limitations           
          on collection commenced upon the assessments of the tax in 2001             
          and therefore does not expire until sometime in 2011.  See sec.             
          6502(a).                                                                    
          III. Issues Other Than the Underlying Tax Liability                         
               A.   Section 6330(c)(1) Verification                                   
               Petitioner also argues, without citing any specifics, that             
          the Appeals employee conducting his section 6330 hearing failed             
          to satisfy section 6330(c)(1), which requires that the Appeals              
          officer obtain verification that the requirements of applicable             
          law or administrative procedure have been met.  We disagree.  The           
          notice of determination catalogues the investigation undertaken             
          by the Appeals employee to satisfy section 6330(c)(1), petitioner           
          cites no specific error, and we have likewise found no infirmity            
          in the process by which the liabilities at issue were assessed.             
          A portion of the unpaid liability was assessed after being                  









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