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set forth in section 6213(a), respondent assessed the disputed
liabilities.
A taxpayer may contest his or her underlying tax liability
in a section 6330 proceeding only if he or she did not receive a
notice of deficiency for the taxes at issue or did not otherwise
have an opportunity to dispute the tax liability. Sec.
6330(c)(2)(B). Petitioner received notices of deficiency for
1993 and 1994. Consequently, petitioner, as a matter of law, was
not entitled to dispute the existence or amount of the underlying
tax liabilities for those years in a section 6330 proceeding.
2. The Appropriateness of the Proposed Collection
Action
Petitioner does not allege that the administrative
proceeding in this case was defective. She alleges only that she
has no money. We interpret petitioner’s allegation as a
contention that the liabilities are uncollectible due to her
inability to pay.
We begin by noting that the material facts are not in
dispute. Petitioner has unpaid Federal income tax liabilities
for 1993 and 1994. Respondent issued a notice of intent to levy
to petitioner and advised her of her right to request a section
6330 hearing. Because petitioner had received notices of
deficiency for the years at issue, petitioner was not entitled to
contest the underlying liabilities. Sec. 6330(c)(2)(B).
Petitioner’s only recourse was to demonstrate that the proposed
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