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indicated, where, as here, the underlying tax liability is not at
issue, the Tax Court’s review is limited to determining whether
the Commissioner abused his discretion when issuing the notice of
determination. See Goza v. Commissioner, 114 T.C. at 181-182.
The Court is not authorized to provide the relief petitioner
requests. As a result, the Court will deny petitioner’s motions.
An appropriate order and
decision will be entered.
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Last modified: March 27, 2008