Eryck C. Aston - Page 6

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          generally shall be conducted consistent with the procedures set             
          forth in section 6330(c), (d), and (e).  Sec. 6320(c).                      
               Section 6330(a) provides that the Secretary shall furnish              
          taxpayers with written notice of their right to a hearing before            
          any property is levied upon.  Section 6330 further provides that            
          the taxpayer may request administrative review of the matter (in            
          the form of a hearing) within a prescribed 30-day period.  Sec.             
          6330(a) and (b).                                                            
               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 otherwise had the                   
          opportunity to dispute 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.                                                                    
               Respondent concedes that (1) petitioner did not receive the            
          statutory notices of deficiency for 1987, 1988, 1989, and 1992,             
          (2) petitioner raised the issue of his underlying liability for             






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