Said M. Karara - Page 6

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          receive a statutory notice of deficiency or otherwise receive an            
          opportunity to dispute the liability.  Sec. 6330(c).                        
               Petitioner and an impartial Appeals officer conducted an               
          administrative hearing comprising three separate telephone calls.           
          For purposes of the hearing, petitioner and respondent agreed to            
          place petitioner’s 1993 and 1994 tax years at issue.  Because               
          this Court had previously entered a decision, the merits of                 
          petitioner’s underlying tax liability were not at issue at the              
          administrative hearing and are not at issue here.  Therefore, we            
          review respondent’s administrative determination to proceed with            
          collection for an abuse of discretion.  Sec. 6330(c)(2)(B); Sego            
          v. Commissioner, 114 T.C. 604, 610 (2000).  Because petitioner              
          was not entitled to question the underlying tax liability, his              
          administrative hearing was limited to collection issues,                    
          including spousal defenses, the appropriateness of respondent’s             
          intended collection action, and collection alternatives.                    
          Petitioner raises two issues with respect to the appropriateness            
          of respondent’s collection actions.2                                        
               Respondent assessed petitioner’s 1993 and 1994 tax                     
          liabilities on December 12, 1999.  On July 29, 2000, respondent             
          issued to petitioner a Final Notice-–Notice of Intent to Levy and           
          Notice of Your Right to a Hearing for his 1994 tax year.  On                


               2 Petitioner does not challenge his underlying tax                     
          liability, but rather challenges respondent’s ability to collect.           
          Petitioner contends that there was a waiver or some form of                 
          estoppel connected with respondent’s waiver of respondent’s right           
          to respond to petitioner’s petition for writ of certiorari.                 



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