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proceeding regarding a Federal tax lien by way of the
cross-reference contained in section 6320(c).
Petitioner's conduct in his earlier deficiency case at
docket No. 13410-00, coupled with his actions in this proceeding,
clearly demonstrates that petitioner exploited the collection
review procedures primarily for the purpose of delay. As
discussed below, petitioner’s arguments have absolutely no merit.
Moreover, petitioner ignored the opportunity that the Court
extended to him at trial to assert a legitimate claim for
relief.5
As previously mentioned, petitioner asserted that the
notices of deficiency that respondent issued to him for 1993 to
1997 are invalid. This precise issue was previously considered
and rejected by the Court when the Court denied petitioner’s
motion to dismiss filed at docket No. 13410-00. The Court’s
Order and Order of Dismissal and Decision entered at docket No.
13410-00 was affirmed on appeal and is now final. Sec. 7481. It
follows that petitioner is barred from challenging either the
validity of the notices of deficiency or the existence or amount
5 Under the circumstances, petitioner has given us no
reason to believe that remanding this matter to respondent's
Appeals Office would be productive or otherwise advance the
policies underlying secs. 6320 and/or 6330. Consistent with our
reasoning in Keene v. Commissioner, 121 T.C. 8, 19-20 (2003), and
in Kemper v. Commissioner, T.C. Memo. 2003-195, we conclude that
a remand is unwarranted.
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Last modified: May 25, 2011