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Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520 (1992), affd.
17 F.3d 965 (7th Cir. 1994); Zaentz v. Commissioner, 90 T.C. 753,
754 (1988). The moving party bears the burden of proving that
there is no genuine issue of material fact. Dahlstrom v.
Commissioner, 85 T.C. 812, 821 (1985); Jacklin v. Commissioner,
79 T.C. 340, 344 (1982).
B. Analysis
Petitioners do not challenge the existence or amounts of
their underlying income tax liabilities for the years in issue.
Where the taxpayer’s underlying tax liability is not at issue, we
review the Commissioner’s administrative determination for abuse
of discretion. Sego v. Commissioner, 114 T.C. 604, 610 (2000);
Goza v. Commissioner, 114 T.C. 176, 181 (2000).
There are no genuine issues of material fact. We conclude
that summary judgment is appropriate. See Rule 121(b).
1. Whether We Have Jurisdiction Over Employment Taxes
Petitioners contend that respondent erroneously tried to
collect employment taxes related to petitioner’s law corporation
from petitioners. We lack jurisdiction to decide that issue.
Moore v. Commissioner, 114 T.C. 171, 175 (2000).
2. Whether We Have Jurisdiction To Decide Whether
Respondent Sent Notices of Federal Tax Liens to
Petitioners’ Last Known Address
Petitioners contend that respondent did not send notice of
the Federal tax liens for tax years 1991, 1993, and 1995 to their
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