Raymond Wright - Page 6




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          one reflecting changes to his account for 1987 and the other                
          reflecting changes to his account for 1989.  The notice for 1987            
          credited petitioner’s account $2,346 for tax withheld and abated            
          $3,260.71 in interest.  The notice for 1989 credited petitioner’s           
          account $278 for tax withheld.                                              
          Unpaid Balance                                                              
               As of March 11, 2002, petitioner had unpaid income tax                 
          liabilities, including penalties and interest, for 1987 and 1989            
          of $3,213.73 and $9,070.31, respectively.                                   
                                       OPINION                                        
               Pursuant to section 6330(c)(2)(A), a taxpayer may raise at             
          the section 6330 hearing any relevant issue with regard to the              
          Commissioner’s collection activities, including spousal defenses,           
          challenges to the appropriateness of the Commissioner’s intended            
          collection action, and alternative means of collection.  Sego v.            
          Commissioner, 114 T.C. 604, 609 (2000); Goza v. Commissioner, 114           
          T.C. 176, 180 (2000).  If a taxpayer received a statutory notice            
          of deficiency for the years in issue or had the opportunity to              
          litigate the underlying tax liability, the taxpayer is precluded            
          from challenging the existence or amount of the underlying tax              
          liability.  Sec. 6330(c)(2)(B); Sego v. Commissioner, supra at              
          610-611; Goza v. Commissioner, supra at 182-183.  Additionally, a           
          taxpayer is precluded from relitigating issues raised and                   
          considered in any previous Appeals hearing or any other                     






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