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Although the term “underlying tax liability” is defined in
neither sections 6320 and 6330 nor the legislative history,
Congress’ intent in ensuring due process to taxpayers when the
Commissioner seeks to collect taxes by liens or levies suggests
that the term includes any amounts owed that are the subject of
the Commissioner’s collection activities.14 See H. Conf. Rept.
105-599, supra at 263-267. We, therefore, interpret the term
“underlying tax liability” in section 6330(d)(1) to include any
amounts owed by a taxpayer pursuant to the tax laws. In this
case, the underlying tax liability includes the tax deficiency,
additions to tax, and statutory interest. We, therefore, must
decide whether we have jurisdiction over the tax deficiency,
additions to tax, and interest that are the subject of
respondent’s collection activities, in order to review the
Appeals officer’s determination pursuant to section 6330 (and
petitioner’s contentions) with regard to each of those amounts.
Review of Tax Deficiency and Additions to Tax
We generally have deficiency jurisdiction to redetermine
deficiencies in income taxes and related additions to tax. See
secs. 6211, 6213(a), 6214(a); see also Goza v. Commissioner, 114
T.C. 176, 182 (2000); Moore v. Commissioner, supra at 175. We,
therefore, have jurisdiction to review the Appeals officer’s
determination in this case insofar as it relates to the assessed
14 References to “collection activities” are to the
Commissioner’s attempts to collect unpaid taxes through the
filing of a lien or the making of a levy.
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