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intrusiveness of the proposed collection action. Sec.
6330(c)(3). The taxpayer may petition the Tax Court or, in
limited cases, a Federal District Court for judicial review of
the Appeals Office’s determination. Sec. 6330(d).
If the taxpayer files a timely petition for judicial review,
the applicable standard of review depends on whether the
underlying tax liability is at issue. Where the underlying tax
liability is properly at issue, the Court reviews any
determination regarding the underlying tax liability de novo.
Sego v. Commissioner, supra at 610. The Court reviews any other
administrative determination regarding the proposed levy action
for abuse of discretion. Id.
With respect to petitioner’s 1997, 1998, and 1999 income tax
liabilities, petitioner did not receive a notice of deficiency.
We assume arguendo that petitioner’s underlying tax liabilities
are properly at issue, and we review his challenge to the
underlying tax liabilities de novo. See Horn v. Commissioner,
T.C. Memo. 2002-207.
A. Petitioner’s Challenge to the Underlying Tax Liabilities
Petitioner contends that he is not subject to Federal income
taxes for the taxable years 1997, 1998, and 1999. In support of
his position, petitioner advances only frivolous4 arguments. We
4Petitioner’s arguments included the following:
(continued...)
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