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action, and possible alternative means of collection. A taxpayer
may contest the existence or amount of the underlying tax
liability at an Appeals Office hearing only if the taxpayer did
not receive any statutory notice of deficiency for the tax
liability or did not otherwise have an opportunity to dispute the
tax liability. Sec. 6330(c)(2)(B); see Sego v. Commissioner, 114
T.C. 604, 609 (2000); Goza v. Commissioner, 114 T.C. 176, 180-181
(2000). Moreover, except in certain limited circumstances, a
person is generally precluded from raising at the Appeals Office
hearing any issue raised and considered in any previous
administrative or judicial proceeding. Sec. 6330(c)(4).
Where the validity of the underlying tax liability is
properly at issue, we review that issue de novo. See Sego v.
Commissioner, supra at 610. Other issues we review for abuse of
discretion. Id. On brief, petitioner acknowledges that he “has
not challenged the validity of the tax liability” and that we
should review respondent’s determination in this collection
proceeding for abuse of discretion.
B. Verification Requirement
Petitioner contends that the Appeals officer failed to
obtain verification from the Secretary that the requirements of
all applicable laws and administrative procedures had been met as
required by section 6330(c)(1).
Section 6330(c)(1) does not require the Commissioner to rely
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