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deficiency, but he did not file a petition with respect to that
notice. On the instant record, we find that petitioner may not
challenge the underlying tax liability for any of his taxable
years 1993, 1994, or 1995. See sec. 6330(c)(2)(B).2
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.3 Sego v. Commissioner, 114 T.C. 604,
610 (2000); Goza v. Commissioner, 114 T.C. 176, 182 (2000).
In support of his position that respondent may not proceed
with the collection action as determined in the notice of deter-
mination with respect to his taxable years 1993, 1994, and 1995,
petitioner argues that respondent did not comply with the collec-
tion procedures set forth in the Code. On the instant record, we
find that respondent complied with the applicable collection
procedures. See sec. 6320.
Based upon our examination of the entire record before us,
we find that respondent did not abuse respondent’s discretion in
determining to proceed with the collection action as determined
in the notice of determination with respect to petitioner’s
2All section references are to the Internal Revenue Code
(Code) in effect at all relevant times.
3Assuming arguendo that petitioner had properly placed at
issue the validity of the respective underlying tax liabilities
for his taxable years 1993, 1994, and 1995, on the record before
us, we find that such liabilities are valid.
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