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after section 6330's effective date. See Goza v. Commissioner,
supra at 182-183 (holding that receipt of a notice of deficiency
issued prior to January 19, 1999, precluded the taxpayer from
challenging the underlying liability). We need not decide
whether review of Appeals’ denial of the extension request is
precluded by section 6330(c)(4) because the Appeals’ denial was
raised by the estate and reconsidered by respondent. Indeed,
respondent stated in the determination: “We have reconsidered
your request for extension of time to pay and have concluded that
the decision of the appellate conferee was correct and not an
abuse of discretion.” In sustaining the extension denial, the
Appellate conferee asserted his objection to allowing
distributions to the beneficiary prior to payment of the estate’s
tax liability, and found unpersuasive the estate’s contention
that it could not pay the estate tax liability because it could
not “borrow * * * except at a rate of interest higher than that
generally available”. Respondent’s refusal to reverse the
Appellate conferee’s decision was not an abuse of discretion.
II. The Request for Abatement
The estate contends that it was entitled to raise, and have
considered at the hearing, its request for abatement. Respondent
contends that this issue could not be raised during the hearing
because the estate took advantage of the opportunity to challenge
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