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underlying tax liability. Sec. 6330(c)(2)(B); Sego v.
Commissioner, supra at 610-611; Goza v. Commissioner, supra at
182-183.
1. 1992 and 1993
Our jurisdiction under section 6330(d) allows us in a lien
or levy proceeding to redetermine an underlying tax liability
that is entirely self-assessed, although the liability is not a
deficiency. Montgomery v. Commissioner, 122 T.C. 1 (2004).
Section 6330(c)(2) provides that a taxpayer may raise any
“relevant” issue at the collection hearing. Petitioner made only
groundless and frivolous arguments.
Petitioner’s challenge to the existence of his tax liability
is meritless. The tax assessments generating the levy for 1992
and 1993 are based on the tax shown on returns petitioner filed
under penalties of perjury. See sec. 6201(a)(1).
Petitioner questioned the validity of those liabilities
during his hearing. Petitioner advanced frivolous arguments
during this hearing. Petitioner continued to advance his
groundless arguments in his petition, in his opposition to
summary judgment, and at the hearing on the motion. Despite
petitioner’s assertions to the contrary, there is no genuine
issue as to the existence of his 1992 and 1993 unpaid tax. And
because petitioner challenged only the existence of a law
requiring him to pay a Federal tax on his earnings and did not
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