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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.
A. Summary Judgment
Petitioner challenges the assessments made against him on
the ground that the notices of deficiency issued to him are
invalid. However, the record shows that petitioner received the
notices 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) generally bars petitioner
from challenging the existence or amount of his underlying tax
liabilities in this collection review proceeding.
Even if petitioner were permitted to challenge the validity
of the notices of deficiency, petitioner’s argument that the
notices are invalid because respondent’s Service Center director
is not properly authorized to issue notices of deficiency is
frivolous and groundless. See Nestor v. Commissioner, 118 T.C.
162, 165 (2002); Goza v. Commissioner, supra. Further, as the
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