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collection alternatives with Michael Keown, but he was
not interested. Given the taxpayers’ continued non-
compliance, the government should be allowed to proceed
with its proposed enforcement action, its intent to
levy. Lacking the taxpayers’ cooperation, the proposed
collection action balances the need for efficient
collection with the taxpayer’s [sic] concern that any
collection action be no more intrusive than necessary.
Discussion
The Court may grant summary judgment where there is no
genuine issue of material fact and a decision may be rendered as
a matter of law. Rule 121(b); Sundstrand Corp. v. Commissioner,
98 T.C. 518, 520 (1992), affd. 17 F.3d 965 (7th Cir. 1994). We
conclude that there is no genuine issue of material fact regard-
ing the questions raised in respondent’s motion.
A taxpayer may raise challenges to the existence or the
amount of the taxpayer’s underlying tax liability if the taxpayer
did not receive a notice of deficiency or did not otherwise have
an opportunity to dispute the tax liability. Sec. 6330(c)(2)(B).
Where the validity of the underlying tax liability is properly
placed at issue, the Court will review the matter on a de novo
basis. Sego v. Commissioner, 114 T.C. 604, 610 (2000); Goza v.
Commissioner, 114 T.C. 176, 181-182 (2000). Although petitioners
did not receive a notice of deficiency with respect to their
taxable year 1999, the contentions that petitioners raised at
their Appeals Office hearing and in their petition with respect
to petitioners’ unpaid liability for 1999 are that they “had no
statutory income to report”, that wages are not income, and that
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