Yakuba G. Brown - Page 6

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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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