Kelly V. Kaeckell - Page 7




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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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