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OPINION
A. Hearing Issue
Petitioner’s only argument at trial was that he did not
receive a proper hearing. Petitioner was given an opportunity at
trial and on brief to raise any issues that he might have raised
at a hearing such as spousal defenses, collection alternatives,
and challenges to the appropriateness of the collection action,
pursuant to section 6330(c). Petitioner did not raise any of
these issues at trial, and he failed to file a posttrial brief
with the Court. Petitioner presented various arguments in his
Form 12153 and his petition, but all of these arguments are based
on legal propositions that this Court has previously rejected.
Petitioner has not raised any relevant issues and has not shown
that he would raise relevant issues at a hearing. Consequently,
even if we were to find that petitioner did not receive a
hearing, the applicable law would not compel us to hold in his
favor. See Lunsford v. Commissioner, 117 T.C. 183, 189 (2001).
Therefore, we find it unnecessary to address the issue of whether
petitioner received a hearing. Instead, we will briefly address
each of the arguments petitioner raised in his request for a
hearing and in his petition.
B. Procedural Challenges
Petitioner claims that he may challenge his underlying
liability because he did not receive a valid notice of deficiency
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Last modified: May 25, 2011