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not receive a notice of deficiency or did not otherwise have an
opportunity to dispute that tax liability. Sec. 6330(c)(2)(B);
see Sego v. Commissioner, 114 T.C. 604, 609 (2000); Goza v.
Commissioner, 114 T.C. 176, 180-181 (2000).
If the validity of the underlying tax liability is properly
at issue, we review that issue de novo. See Sego v.
Commissioner, supra at 609-610. Other issues we review for abuse
of discretion. Id.
B. Petitioner’s Contentions
1. Underlying Tax Liability
In his petition, petitioner challenges his underlying 1987
tax liability. Because petitioner received a notice of
deficiency for the 1987 tax year, he is not entitled to challenge
the existence or amount of his 1987 tax liability in this
collection proceeding. See secs. 6320(c), 6330(c)(2)(B); Sego v.
Commissioner, supra at 609; Goza v. Commissioner, supra at
180-181.4
2. Installment Agreement
AO Szalkowski considered alternative means of collection and
prepared an installment agreement, which petitioner ultimately
4 AO Szalkowski reviewed the underlying 1987 tax liability
despite petitioner’s receipt of the 1987 notice of deficiency.
This action does not constitute a waiver of the statutory bar and
does not empower this Court to review petitioner’s challenge to
his underlying tax liability. See Behling v. Commissioner, 118
T.C. 572, 577-579 (2002); sec. 301.6320-1(e)(3), Q&A-E11, Proced.
& Admin. Regs.
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