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seeks to collect are income taxes over which the Court normally
has jurisdiction. See secs. 6211, 6213. Thus, despite the fact
that petitioner failed to invoke the Court's deficiency
jurisdiction by filing a petition for redetermination contesting
the notice of deficiency for 1994, 1995, and 1996, we hold that
section 6330(d) vests the Court with jurisdiction to review
respondent's administrative determination to proceed with a levy
to effect the collection of the taxes due from petitioner for
those years.
Sufficiency of the Petition for Review
Section 6330(c)(2)(A) prescribes the issues that may be
raised by a taxpayer in an Appeals Office due process hearing,
including spousal defenses to collection, challenges to the
appropriateness of the Commissioner's intended collection action,
and offers of alternative means of collection. Section
6330(c)(2)(B) provides that the Appeals Office due process
hearing is not a forum for the taxpayer to contest the existence
or amount of the underlying taxes unless the taxpayer did not
receive a notice of deficiency for the taxes in question or did
not otherwise have an earlier opportunity to dispute such tax
liability.
Although petitioner received a notice of deficiency for the
taxable years 1994, 1995, and 1996, he did not avail himself of
the opportunity to file a petition for redetermination with the
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