Yvonne Thomas - Page 9

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          an issue as to the amount of a taxpayer’s tax liability.  We need           
          not and do not address that issue.                                          
               None of the exceptions petitioner asks us to recognize are             
          valid.  Under section 6330(c)(2)(B), petitioner is precluded from           
          challenging herein the amount of her 2002 Federal income tax                
          liability.  Evidence relating to petitioner’s 2002 Federal income           
          tax liability is not relevant and will not be admitted.2                    
               For the reasons stated, we shall deny petitioner’s motions             
          in limine, but we shall grant respondent’s motion in limine.                
               The issue as to petitioner’s claim for interest abatement              
          will be set for subsequent hearing.                                         
                                                  An appropriate order will           
                                             be issued.                               

               2  We note that in certain circumstances under sec. 6201(d)            
          respondent is required to seek reasonable verification of                   
          taxpayer income reported by third parties on information returns            
          such as Forms 1099-B.  For this verification requirement to be              
          triggered, however, a taxpayer must have cooperated with                    
          respondent during respondent’s audit.  Here, petitioner did not             
          participate in the audit, and sec. 6201(d) has no application.              

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