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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 had received a notice of deficiency, yet failed
to file a petition for redetermination with the Court. When the
taxpayer subsequently attempted to use the Court's procedures
governing Lien and Levy Actions as a forum to assert frivolous
and groundless constitutional arguments against the Federal
income tax, we cited the statutory limitation imposed under
section 6330(c)(2)(B) and dismissed the petition for failure to
state a claim upon which relief could be granted.6
Based on our review of the record in this case, we hold that
there is no dispute as to a material fact and that respondent is
entitled to partial summary judgment as a matter of law. In
particular, the record in the instant case shows that petitioner
received notices of deficiency for the taxable years 1980, 1981,
1982, and 1983. Morever, petitioner filed petitions with the
Court contesting those notices. As previously discussed, those
petitions were disposed of either by stipulated decision, order
6 In Goza v. Commissioner, 114 T.C. 176 (2000), the
Commissioner moved to dismiss for failure to state a claim before
filing an answer. In the present case, respondent did not move
for partial summary judgment until well after the case was at
issue within the meaning of Rule 38.
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