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an earlier opportunity to dispute such tax liability. Section
6330(d)(1)(A) provides that a taxpayer may file a petition for
review of the Commissioner's administrative determination with
the Tax Court if the Court has jurisdiction of the underlying tax
liability.
Summary judgment is intended to expedite litigation and
avoid unnecessary and expensive trials. See Florida Peach Corp.
v. Commissioner, 90 T.C. 678, 681 (1988). Summary judgment may
be granted with respect to all or any part of the legal issues in
controversy "if the pleadings, answers to interrogatories,
depositions, admissions, and any other acceptable materials,
together with the affidavits, if any, show that there is no
genuine issue as to any material fact and that a decision may be
rendered as a matter of law." Rule 121(b); Sundstrand Corp. v.
Commissioner, 98 T.C. 518, 520 (1992), affd. 17 F.3d 965 (7th
Cir. 1994); Zaentz v. Commissioner, 90 T.C. 753, 754 (1988);
Naftel v. Commissioner, 85 T.C. 527, 529 (1985).
In Goza v. Commissioner, 114 T.C. 176 (2000), we explained
that section 6330(c) provides for an Appeals Office hearing to
address collection issues such as spousal defenses, the
appropriateness of the Commissioner's intended collection
activities, and possible alternative means of collection. The
taxpayer in Goza received a notice of deficiency, yet failed to
file a petition for redetermination with the Court. When the
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