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that petitioner may not challenge his underlying tax liabilities
for 1995 and 1996.
B. 1999
With respect to the 1999 year, the unpaid balance of
$1,148.09 is based on the tax liability self-reported by
petitioner on his filed return. Petitioner in his amended
petition indicated that he believed his liability for 1999 should
be $1,100. At trial, however, petitioner explained that he had
just rounded the figure in preparing the amended petition and did
agree to the $1,148.09 amount. Therefore, while section
6330(c)(2)(B) does not preclude taxpayers from challenging self-
reported liabilities, Montgomery v. Commissioner, 122 T.C. ___,
___ (2004) (slip op. at 14), it is clear that petitioner does not
propose to do so here.
III. Review for Abuse of Discretion
In light of our conclusions supra regarding challenges to
the underlying liabilities, disposition of this case rests upon
whether the record reflects an abuse of discretion on the part of
respondent in determining to proceed with collection efforts in
the form of a filed lien. Action constitutes an abuse of
discretion under this standard where arbitrary, capricious, or
without sound basis in fact or law. Woodral v. Commissioner, 112
T.C. 19, 23 (1999). The Court considers whether the Commissioner
committed an abuse of discretion in rejecting a taxpayer’s
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