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petitioner’s unpaid liability for 1998. See sec. 6330(c)(2)(B);
Sego v. Commissioner, 114 T.C. 604, 610-611 (2000); Goza v.
Commissioner, 114 T.C. 176, 182-183 (2000).
Where, as is the case here, the validity of the underlying
tax liability is not properly placed at issue, the Court will
review the determination of the Commissioner of Internal Revenue
for abuse of discretion. Sego v. Commissioner, supra at 610;
Goza v. Commissioner, supra at 181-182.
As was true of petitioner’s attachment to her 1998 return,
petitioner’s April 15, 2000 letter, petitioner’s attachment to
her Form 12153, and petitioner’s May 7, 2002 letter, petitioner’s
response contains contentions, arguments, statements, and re-
quests that the Court finds to be frivolous and/or groundless.
To illustrate, petitioner appears to argue that she did not
receive proper notice and demand under section 6303(a) because,
according to petitioner, respondent must use Form 17 in issuing
such notice and demand.
We reject petitioner’s argument that respondent did not
issue the notice and demand required by section 6303(a). Form
4340 with respect to petitioner’s taxable year 1998 shows that
respondent sent petitioner a notice of balance due on July 24,
2000, the same day on which respondent assessed petitioner’s tax,
as well as any penalties and interest as provided by law, for her
taxable year 1998. A notice of balance due constitutes the
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