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amount of the unpaid tax for the taxable period. Further,
section 6330(a)(3)(B) provides that the prescribed notice shall
explain that the person has the right to request an Appeals
Office hearing during the 30-day period under the paragraph (2).
Section 6330(c) prescribes the matters that may be raised by
a taxpayer at an Appeals Office hearing. The section provides
that a taxpayer may raise collection issues such as spousal
defenses, the appropriateness of the Commissioner’s intended
collection action, and possible alternative means of collection,
such as an offer in compromise. Section 6330(c)(2)(B) provides
that the existence and amount of the underlying tax liability can
be contested at an Appeals Office hearing only if the taxpayer
did not receive a notice of deficiency for the taxes in question
or did not otherwise have an earlier opportunity to dispute such
tax liability. Goza v. Commissioner, 114 T.C. 176, 179 (2000).
Where the Appeals Office issues a determination letter to a
taxpayer following an administrative hearing, section 6330(d)(1)
provides that the taxpayer will have 30 days to file a petition
for review with the Tax Court or Federal District Court. Craig
v. Commissioner 119 T.C. 252, 257-258 (2002); Moorhous v.
Commissioner, 116 T.C. 263, 268 (2001). We have held that the
Court’s jurisdiction under sections 6320 and 6330 depends on the
issuance of a valid determination letter and the filing of a
timely petition for review. Craig v. Commissioner, supra at 256;
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