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issues regarding alternative collection activity.
Discussion
Issues that may be raised by a taxpayer at a section 6330(d)
administrative hearing are prescribed by statute, and include, as
relevant here, a challenge to the existence or amount of the
underlying tax liability if the taxpayer did not receive a
statutory notice of deficiency or did not otherwise have an
opportunity to dispute the underlying tax liability. See sec.
6330(c)(2)(A) and (B); Kennedy v. Commissioner, 116 T.C. 255, 260
(2001). If the validity of the underlying tax liability is at
issue, our review of respondent’s determination with respect to
that liability is de novo. See Sego v. Commissioner, 114 T.C.
604, 609-610 (2000).
In this case, we focus our attention on petitioner’s
challenge to the amount of his 1992 Federal income tax liability,
as reported on his 1992 Federal income tax return,1 as he has
raised no other issues either at the section 6330(d)
administrative hearing or before this Court. See Rule 331(b)(4);
Pierson v. Commissioner, 115 T.C. 576, 580 (2000). We further
limit our focus to the income reported on the Form 1099 issued by
1 Under the circumstances of this case, we decline to
consider whether the manner in which petitioner’s 1992 Federal
income tax return was prepared and filed provided him with an
opportunity to dispute the underlying tax liability reported on
that return. See Horn v. Commissioner, T.C. Memo. 2002-207;
Young v. Commissioner, T.C. Memo. 2003-6.
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