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(1) Whether petitioner’s arguments that
(a) Synergistics/Blueprint Software (Synergistics), Lumenetics,
and Data Flex partnerships were not properly subjected to the
unified audit and litigation procedures of sections 6221 through
6234 (hereinafter referred to as TEFRA procedures), for taxable
years 1982, 1983, and 1984, and (b) Dennis R. DiRicco (DiRicco)
was ineligible to serve as tax matters partner (TMP) of the
partnerships may be considered in this case;
(2) if so, whether respondent’s Appeals officer properly
determined, during the section 6330 hearing (hearing), that
petitioner was precluded by section 6330(c)(2)(B) from
challenging the use of TEFRA audit procedures in the previous
cases;
(3) whether respondent’s criminal investigation of
petitioner converted the partnership items on his tax returns to
nonpartnership items in 1982, 1983, and 1984;
(4) whether petitioner was denied due process by being
unable to access records allegedly held by respondent; and,
ultimately,
(5) whether there was an abuse of discretion by the Appeals
officer of the Internal Revenue Service (IRS) in determining that
collection of petitioner’s unpaid income tax liabilities for
1982, 1983, and 1984 should proceed.
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