Michael Schaper - Page 8




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          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.  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 that 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.                   
               B.  Summary Judgment                                                   
               Petitioner challenges the assessments made against him on              
          the ground that the notice of deficiency dated March 3, 2000, is            
          invalid.  However, the record shows that petitioner received the            
          notice of deficiency and disregarded the opportunity to file a              






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