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existence or amount of his underlying tax liabilities in this
proceeding. Petitioner did not raise any other relevant issues,
such as “appropriate spousal defenses, challenges to the
appropriateness of collection actions, and offers of collection
alternatives”, see sec. 6330(c)(2)(A), in his request for a
section 6330 hearing, at the hearing before respondent’s Appeals
officer, or in his petition to this Court.
Section 6330(c)(2)(B) provides:
(B) Underlying liability.--The person may also
raise at the hearing challenges to the existence or
amount of the underlying tax liability for any tax
period if the person did not receive any statutory
notice of deficiency for such tax liability or did not
otherwise have an opportunity to dispute such tax
liability. [Emphasis added.]
Petitioner did not receive a notice of deficiency for any of
the years in issue. Petitioner has claimed that he may challenge
the existence or amount of his underlying tax liabilities in this
proceeding because he did not “otherwise have an opportunity to
dispute * * * [his] tax liability” within the meaning of section
6330(c)(2)(B). We must therefore address whether the validity of
the underlying tax liability is properly in issue for any of the
tax years before us.
Petitioner’s Challenges to His 1990 and 1991-1993 Tax Liabilities
Respondent claims that petitioner, by signing Forms 4549-CG
for 1990 through 1993, waived his right to challenge the proposed
assessments and should be deemed to have had an opportunity to
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