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dated June 16, 2000, were “seriously flawed” in that they were
issued at a time when “no assessed liability against the
petitioner even existed” and that (2) such notices were otherwise
“premature”. However, the record shows that petitioner received
the notices of deficiency and disregarded the opportunity to file
a petition for redetermination with this Court. See sec.
6213(a). It follows that section 6330(c)(2)(B) bars petitioner
from challenging the existence or amount of his underlying tax
liabilities in this collection review proceeding. See Nestor v.
Commissioner, 118 T.C. 162, 165-166 (2002).
Even if petitioner were permitted to challenge the existence
or amount of his underlying tax liabilities, his arguments that
the notices were “seriously flawed” and otherwise “premature” are
frivolous and groundless. See Monaco v. Commissioner, T.C. Memo.
1998-284 (categorically rejecting the argument that the
Commissioner may not determine a deficiency without first making
an assessment); see also Corcoran v. Commissioner, T.C. Memo.
2002-18 (rejecting the argument that the issuance of a notice of
deficiency may not precede a 30-day letter or an administrative
hearing); Trueblood v. Commissioner, T.C. Memo. 1997-524 (same);
Ruff v. Commissioner, T.C. Memo. 1990-521 (same). Likewise, the
argument that petitioner may still be making regarding the
authority of respondent’s service center director to issue
deficiency notices is frivolous and groundless. See Nestor v.
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