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determination. Davis v. Commissioner, 115 T.C. 35, 37 (2000);
Goza v. Commissioner, 114 T.C. 176, 179 (2000). In the event of
such a judicial review, the Court’s standard of review depends on
whether the underlying tax liability is at issue. The Court
reviews a taxpayer’s liability under the de novo standard where
the validity of the underlying tax liability is at issue. The
Court reviews other administrative determinations for abuse of
discretion. Sego v. Commissioner, 114 T.C. 604, 610 (2000). A
taxpayer’s underlying tax liability may be at issue if he or she
“did not receive any statutory notice of deficiency for such tax
liability or did not otherwise have an opportunity to dispute
such tax liability.” Sec. 6330(c)(2)(B).
Here, respondent notified petitioner that he was proposing
to levy upon petitioner’s property in order to collect
petitioner’s Federal income tax debt for 1994, 1995, and 1996.
Following the determination by Appeals that respondent’s proposed
levy was proper, petitioner sought relief in this Court. In
order to decide this case, we focus on assignments of error set
forth in the petition that commenced this proceeding. Rule
331(b)(4) (“Any issue not raised in the assignments of error
shall be deemed to be conceded.”).
Petitioner asserts in his petition numerous allegations of
error in the Appeals officer’s determination. Many of these
allegations are either frivolous and groundless or irrelevant to
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