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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 tax in question or did not otherwise
have an earlier opportunity to dispute the tax liability. 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.
A. Summary Judgment
Petitioner challenges the assessment made against him on the
ground that the notice of deficiency dated August 11, 2000, is
invalid. However, the record conclusively shows that petitioner
received the notice 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
liability in this collection review proceeding. See Nestor v.
Commissioner, 118 T.C. 162, 165-166 (2002).
Even if petitioner were permitted to challenge the validity
of the notice of deficiency, petitioner’s argument that the
notice is invalid because respondent’s Service Center director is
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