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492 (2002) (taxpayer barred under section 6330(c)(4) from raising
at hearing previously litigated statute of limitations issue).
In the absence of a spousal defense, a proper challenge to
the appropriateness of the intended collection action, or an
offer of a viable collection alternative, we shall sustain
respondent’s determination to proceed with the proposed levy.
To reflect the foregoing,
Decision will be entered
for respondent.
6(...continued)
case supports respondent’s position that petitioner and her
husband submitted their offer-in-compromise on Jan. 4, 1990, and,
therefore, the 1998 levy was timely.
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