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conducted consistent with the procedures set forth in section
6330(c), (d), and (e). Sec. 6320(c).
Petitioner argues in his response that he made it clear to
Appeals Officer Otterson that he was willing to pay the amount of
“tax” he owed but not the penalties and interest. Petitioner’s
allegations of error are that respondent did not provide him a
summary of the amounts of the taxes he owed and did not accept
the second OIC. Petitioner does not appear to argue the issue of
“doubt as to liability” with regard to the second OIC.4 In the
second OIC, petitioner did not check the box for doubt as to
liability. In his response, petitioner states that he is willing
to pay the tax without penalties or interest. Furthermore, we
note that although petitioner checked the box for doubt as to
liability on the first OIC, he failed to include a detailed
explanation of the reasons why he believed he did not owe the
tax. Where the validity of the underlying tax liability is not
properly in issue, we review the Commissioner’s determination for
4 We note that petitioner received statutory notices of
deficiency for 1989, 1990, 1991, and 1992, that he failed to
petition the Court with respect to those years, and that his
assessed tax liability for 1993 and 1994 was based upon tax
returns for 1993 and 1994 that he filed on November 28, 1999.
Accordingly, petitioner cannot contest the underlying liabilities
for 1989, 1990, 1991, and 1992. Sec. 6330(c)(2)(B); Sego v.
Commissioner, 114 T.C. 604, 610-611 (2000); Goza v. Commissioner,
114 T.C. 176, 182-183 (2000). Furthermore, petitioner has
admitted his liability for 1993 and 1994. See Lare v.
Commissioner, 62 T.C. 739, 750 (1974), affd. without published
opinion 521 F.2d 1399 (3d Cir. 1975).
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