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in response to these notices of deficiency. Accordingly,
petitioner cannot contest the underlying deficiencies for 1994
and 1996. Sec. 6330(c)(2)(B); Sego v. Commissioner, supra; Goza
v. Commissioner, supra at 182-183. Claims that the limitation
period for assessment has expired are challenges to the
underlying tax liability. Boyd v. Commissioner, 117 T.C. 127,
130 (2001). Additionally, the assessments were timely made.
Therefore, petitioner cannot raise these claims in this
proceeding.
Where the validity of the underlying tax liability is not
properly in issue, we review the Commissioner’s determination for
an abuse of discretion. Sego v. Commissioner, supra at 610.
Petitioner appears to argue that the verification
requirement of section 6330 has not been met. Section 6330(c)(1)
does not require the Commissioner to rely on a particular
document to satisfy the verification requirement imposed therein.
E.g., Schnitzler v. Commissioner, T.C. Memo. 2002-159 (citing
five other cases to support this principle). We have repeatedly
held that the Commissioner may rely on Forms 4340, Certificate of
Assessments, Payments, and Other Specified Matters, or
transcripts of account to satisfy the verification requirement of
section 6330(c)(1). Hromiko v. Commissioner, T.C. Memo. 2003-
107; Schnitzler v. Commissioner, supra; Kaeckell v. Commissioner,
T.C. Memo. 2002-114; Obersteller v. Commissioner, T.C. Memo.
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