Jose A. Perez - Page 8

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          notice and demand, the Secretary may collect such tax by levy on            
          the person’s property.  Section 6331(d) provides that at least 30           
          days before enforcing collection by levy on the person’s                    
          property, the Secretary must provide the person with a final                
          notice of intent to levy, including notice of the administrative            
          appeals available to the person.                                            
               Section 6330 generally provides that the Secretary cannot              
          proceed with collection by levy on any property of any person               
          until the person has been given notice and the opportunity for an           
          administrative review of the matter (in the form of an Appeals              
          Office hearing) and, if dissatisfied, with judicial review of the           
          administrative determination.  Davis v. Commissioner, 115 T.C.              
          35, 37 (2000); Goza v. Commissioner, 114 T.C. 176, 179 (2000).              
          Where the underlying tax liability is not at issue, the Court               
          will review the Appeals officer’s determination for abuse of                
          discretion.  Sego v. Commissioner, 114 T.C. 604, 610 (2000).                
          Collateral Estoppel                                                         
               In an effort to show that respondent’s determination to                
          proceed with collection was an abuse of discretion, petitioner              
          raises several contentions, namely, that with respect to the 1984           
          through 1987 taxes for which collection is sought, no proper                
          assessment of the taxes occurred; that even if assessment                   
          occurred, petitioner received no notice thereof; that no notices            
          of deficiency were issued; and that petitioner’s extension of the           

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