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* * * imposed by this title”. Such authority extends to “all
taxes determined by the taxpayer or by the Secretary” for which a
return is required. Sec. 6201(a)(1). A preliminary step is
required, however, in the case of income, estate, gift, and
certain excise taxes. With respect to those types of taxes, if
the tax imposed exceeds the amount shown (if any) as the tax by
the taxpayer on the required return, the Commissioner (acting for
the Secretary) generally may not assess such deficiency without
first issuing a notice of deficiency to the taxpayer and allowing
the taxpayer to petition this Court for a redetermination of such
deficiency. Secs. 6201(e), 6211(a), 6212, 6213(a), 6214(a), and
6215(a). On the collection side, section 6303(a) provides
generally that the Secretary “shall * * * after the making of an
assessment of a tax * * * give notice to each person liable for
the unpaid tax, stating the amount and demanding payment
thereof.”
When section 6330(c)(2) is read against the backdrop of the
statutory provisions discussed in the preceding paragraph, it
becomes apparent that the term “underlying tax liability”, as
used in section 6330(c)(2)(B), means the tax (which may or may
not be the correct tax) on which the Commissioner based his
assessment (whether such tax is the tax shown on the taxpayer’s
return or the tax determined as a result of an examination by the
Commissioner), whereas the term “unpaid tax”, as used in section
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