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Director and also to the Director of the Service Center who
issued the notices of deficiency in this case. See Stamos v.
Commissioner, 95 T.C. 624, 630-631 (1990), affd. without
published opinion 956 F.2d 1168 (9th Cir. 1992); Kellogg v.
Commissioner, 88 T.C. 167, 172 (1987); Perlmutter v.
Commissioner, 44 T.C. 382, 385 (1965), affd. 373 F.2d 45 (10th
Cir. 1967); secs. 301.6212-1(a), 301.7701-9(b), Proced. & Admin.
Regs. A taxpayer may contest the existence or amount of the
underlying tax liability at the section 6330(b) hearing only if
the taxpayer did not receive a notice of deficiency for such tax
liability or did not otherwise have an opportunity to dispute
such tax liability. Sec. 6330(c)(2)(B). Section 6330(c)(2)(B)
bars petitioner from contesting the existence or amount of his
tax liabilities for 1992-97 because he received notices of
deficiency for those years.
B. Whether Respondent’s Determination To Proceed With
Collection as to Petitioner’s 1992-97 Tax Years Was an Abuse
of Discretion
The Appeals officer verified that the Internal Revenue
Service (IRS) had met the requirements of any applicable laws and
administrative procedures. See sec. 6330(c)(1); sec. 301.6330-
1(e)(1), Proced. & Admin. Regs. The second sentence of section
6203 provides that the Secretary shall, upon request of the
taxpayer, provide the taxpayer a copy of the record of
assessment.
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