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liability. See Sego v. Commissioner, 114 T.C. 604, 609 (2000);
Goza v. Commissioner, 114 T.C. 176, 179 (2000).
Section 6330(d) provides for judicial review of the
administrative determination by this Court or by a Federal
District Court, as may be appropriate. Where the validity of the
underlying tax liability is not properly at issue, the Court will
review the Commissioner’s administrative determination for abuse
of discretion. Where, however, the validity of the underlying
tax liability is properly at issue, this Court will review the
matter on a de novo basis. Sego v. Commissioner, supra at 610;
see H. Conf. Rept. 105-599 at 266 (1998), 1998-3 C.B. 747, 1020.
The Notices of Deficiency Regarding Petitioner’s Tax Liabilities
for 1995 and 1997 Were Not Barred by a Directive From the Office
of the Taxpayer Advocate
Within the IRS is an Office of the Taxpayer Advocate, headed
by the National Taxpayer Advocate. Sec. 7803(c). Among the
functions of the Office of the Taxpayer Advocate is to "assist
taxpayers in resolving problems with the Internal Revenue
Service". Sec. 7803(c)(2)(A)(i). A taxpayer seeking such
assistance may file an application with the Office of the
Taxpayer Advocate for a "Taxpayer Assistance Order" (TAO), which
may be issued if the National Taxpayer Advocate determines that
the taxpayer is or is about to incur "a significant hardship as a
result of the manner in which the internal revenue laws are being
administered" by the IRS. Sec. 7811(a)(1)(A). The Office of
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