Hauptman v. Commissioner

GRUENDER, Circuit Judge.

Bruce A. Hauptman sought judicial review of the Commissioner of Internal Revenue Service’s (“IRS”) notices of determination permitting a levy to collect Hauptman’s unpaid income tax liabilities for tax years 1992 through 1996. The tax court upheld the IRS’s determinations. Hauptman appeals, arguing (1) that the tax court lacked jurisdiction and (2) that the IRS abused its discretion when it rejected Hauptman’s offer-in-compromise. We affirm.

I

Hauptman is an investment consultant who owned controlling interests in firms that managed over $100 million in client funds in…