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121(b); Sundstrand Corp. v. Commissioner, 98 T.C. 518, 520
(1992), affd. 17 F.3d 965 (7th Cir. 1994).
We conclude that there is no genuine issue as to any
material fact and that a decision may be rendered as a matter of
law.
B. Section 6330
Section 6330 provides that the Secretary shall furnish the
person described in section 6331 with written notice (i.e., the
hearing notice) before a levy on any property or right to
property. Sec. 6330(a). Section 6330 further provides that
within a 30-day period the taxpayer may request administrative
review of the matter (in the form of a hearing). The hearing
generally shall be conducted consistent with the procedures set
forth in section 6330(b) and (c).
Pursuant to section 6330(c)(2)(A), a taxpayer may raise at
the section 6330 hearing any relevant issue with regard to the
Commissioner’s collection activities, including spousal defenses,
challenges to the appropriateness of the Commissioner’s intended
collection action, and alternative means of collection. Sego v.
Commissioner, 114 T.C. 604, 609 (2000); Goza v. Commissioner, 114
T.C. 176, 180 (2000). If a taxpayer received a statutory notice
of deficiency for the years in issue or otherwise had the
opportunity to dispute the underlying tax liability, the taxpayer
is precluded from challenging the existence or amount of the
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