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Second, as we understand petitioner’s position, she contends
that she is not liable for the taxes. Petitioner does not allege
that she did not receive the notices of deficiency for the tax
liabilities in issue, nor does she allege that she did not have
an opportunity to contest the deficiencies. Under section
6330(c)(2)(B), a taxpayer is precluded from contesting the
existence or amount of the tax liability at an Appeals Office
hearing or in this Court unless a taxpayer did not receive a
notice of deficiency and did not otherwise have an opportunity to
dispute such tax liability. See Pierson v. Commissioner, 115
T.C. 576, 579 (2000); Goza v. Commissioner, supra at 180-181.
Third, even if petitioner were not precluded from contesting
the liabilities, the arguments that she makes are totally
frivolous.
Finally, it should be pointed out that petitioner has not
contended that any other issue under section 6330(c)(2) should
have been considered. She did not offer any collection
alternative or offer-in-compromise. As to these issues, the
propriety of respondent’s determination is deemed to be conceded.
See Rule 331(b)(4).
In sum, petitioner has not raised any issue that would call
into question the correctness of respondent’s determination to
proceed with the collection of the tax liabilities. Under these
circumstances, it makes no difference whether we grant
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