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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
Petitioners challenge the assessment made against them on
the ground that the notice of deficiency dated June 16, 2000, is
invalid because “respondent did not provide any proof that
Deborah Decker has any legal authority to send out a Notice of
Deficiency”. However, the record conclusively shows that
petitioners 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 petitioners from challenging the existence or amount of
their underlying tax liability in this collection review
proceeding. See Nestor v. Commissioner, 118 T.C. 162, 165-166
(2002).
Even if petitioners were permitted to challenge the validity
of the notice of deficiency, petitioners’ argument that the
notice is invalid because respondent’s Service Center director is
not properly authorized to issue notices of deficiency is
frivolous and groundless. See id. at 165; Goza v. Commissioner,
supra. Likewise, petitioners’ argument that no statute
establishes an individual’s liability for income tax or requires
the payment of income tax is frivolous and groundless. As the
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