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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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