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review of the matter (in the form of an Appeals Office hearing)
and, if 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 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. 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.
Petitioners do not challenge the existence or the amount of
their underlying tax liabilities for the years in question.
Petitioners simply assert that the settlement officer failed,
either before or during the Appeals Office hearing, to verify
that respondent made valid assessments against petitioners for
the taxes alleged to be due. We disagree.
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Last modified: May 25, 2011