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dissatisfied, with judicial review of the administrative
determination. See Davis v. Commissioner, 115 T.C. 35, 37
(2000); Goza v. Commissioner, 114 T.C. 176, 179 (2000).
Section 6330(c) prescribes the matters that a person may
raise at an Appeals Office hearing. In sum, section 6330(c)
provides that a person may raise collection issues such as
spousal defenses, the appropriateness of the Commissioner's
intended collection action, and possible alternative means of
collection. Section 6330(c)(2)(B) provides that the existence
and amount of the underlying tax liability can be contested at an
Appeals Office hearing only if the person did not receive a
notice of deficiency for the taxes in question or did not
otherwise have an earlier opportunity to dispute the tax
liability.4 See Sego v. Commissioner, 114 T.C. 604, 609 (2000);
Goza v. Commissioner, supra. Section 6330(d) provides for
judicial review of the administrative determination in the Tax
Court or a Federal District Court, as may be appropriate.
Petitioner argues that the Appeals officer failed to obtain
verification from the Secretary that the requirements of all
applicable laws and administrative procedures were met as
required by section 6330(c)(1). We reject petitioner’s argument
4 As previously stated, petitioner has admitted that he
received the notice of deficiency dated Sept. 21, 1999.
However, petitioner did not file a petition for redetermination
with the Court challenging the notice of deficiency.
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