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record, we find that petitioners may not challenge the existence
or the amount of petitioners’ unpaid liability for 1996,
petitioners’ unpaid liability for 1997, and petitioners’ unpaid
liability for 1999. See sec. 6330(c)(2)(B); Sego v.
Commissioner, supra; Goza v. Commissioner, supra.
Where, as is the case here, the validity of the underlying
tax liability for each of the years 1996, 1997, and 1999 is not
properly placed at issue, the Court will review the determination
of the Commissioner for abuse of discretion. Sego v.
Commissioner, supra; Goza v. Commissioner, supra.
We turn to the issues that petitioners raised in
petitioners’ attachment to their 1996 Form 12153, in petitioners’
attachment to their 1997 and 1999 Form 12153, in the letters that
petitioners sent to the IRS with respect to their taxable years
1996, 1997, and 1999, at their Appeals Office hearing, and in the
petition and the exhibits attached to the petition, which we
shall review for abuse of discretion. We find petitioners’
attachment to their 1996 Form 12153, petitioners’ attachment to
their 1997 and 1999 Form 12153, the various letters that
petitioners sent to the IRS with respect to their taxable years
1996, 1997, and 1999, and the matters that petitioners raised at
their Appeals Office hearing to be frivolous and/or groundless.3
3We also find petitioners’ attachment to their 1996 Form
1040 and petitioners’ attachment to their 1997 Form 1040A to be
(continued...)
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