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(2002). Moreover, the Appeals officer properly considered all
issues raised by petitioners that were allowable within the
purview of section 6330(c). In that regard, we have held that
petitioners were statutorily precluded from challenging the
underlying tax liability for taxable year 1995.
Accordingly, there was no abuse of discretion in
respondent’s determination to proceed with collection of
petitioners’ 1995, 1996, and 1997 tax liabilities.
To reflect the foregoing,
Decision will be entered
for respondent.
This opinion was modified by Order dated June 18, 2003.
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