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Generally, the proposed levy actions are suspended for the
pendency of the hearing and any judicial appeals therein. Sec.
6330(e)(1).
B. Petitioner’s Contentions
1. Underlying Tax Liability
Petitioner contends that he was improperly precluded at his
Appeals Office hearing from challenging his underlying tax
liability for the 3 tax years at issue. He bases this claim on
the Appeals officer’s refusal to engage in a colloquy with him
regarding his frivolous protestations about the existence of any
legal requirement to pay income taxes, and on his allegation that
the notices of deficiency for the years at issue were invalid
because they were not issued by the Secretary, and because he was
not given a copy of the order delegating authority from the
Secretary to the Director of the Service Center who issued them.
A taxpayer may contest the existence or amount of the
underlying tax liability at an Appeals Office hearing only if the
taxpayer did not receive any statutory notice of deficiency for
the tax liability or did not otherwise have an opportunity to
dispute the tax liability. Sec. 6330(c)(2)(B); see Sego v.
Commissioner, 114 T.C. 604, 609 (2000); Goza v. Commissioner, 114
T.C. 176, 180-181 (2000). Petitioner received notices of
deficiency for the 3 tax years at issue. Petitioner did not
seek redetermination of the deficiencies in this Court. He did,
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