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6323. Section 6320 further provides that the taxpayer may
request administrative review of the matter (in the form of a
hearing) within a prescribed 30-day period. The hearing
generally shall be conducted consistent with the procedures set
forth in section 6330(c), (d), and (e). Sec. 6320(c).
The petition in this case is an eight-page document filled
with frivolous and groundless arguments. It is unclear in the
petition whether petitioner raises the issue of his underlying
liabilities. If he did, petitioner is precluded from challenging
his underlying tax liabilities in the instant proceeding because
he did not challenge them at the hearing. Tabak v. Commissioner,
T.C. Memo. 2003-4; see Miller v. Commissioner, 115 T.C. 582, 589
n.2 (2000), affd. 21 Fed. Appx. 160 (4th Cir. 2001); sec.
301.6320-1(f)(2), Q&A-F5, Proced. & Admin. Regs.; see also sec.
301.6330-1(f)(2), Q&A-F5, Proced. & Admin. Regs.
Where the validity of the underlying tax liability is not
properly in issue, we review respondent’s determination for an
abuse of discretion. Sego v. Commissioner, 114 T.C. 604, 610
(2000).
Petitioner appears to argue that at the hearing he was not
provided documents demonstrating that the verification
requirement of section 6330 had been met. At the hearing, the
Commissioner is not required to provide the taxpayer with a copy
of verification that the requirements of any applicable law or
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