- 11 - respect to which the liabilities at issue in this case were assessed. G. Underlying Tax Liabilities Petitioners also raise several issues that attack the validity of the underlying tax liabilities for 1996 and 1997. Since petitioners received a notice of deficiency with respect to those years and did not petition this Court regarding that notice, they are now precluded from disputing the existence or amount of the underlying tax liabilities. Sec. 6330(c)(2)(B); Nestor v. Commissioner, supra. H. Conclusion Petitioners have not raised any spousal defenses, challenges to the appropriateness of the collection action, or collection alternatives. We have considered every contention raised by petitioners, and conclude that there are no genuine issues of material fact, and that respondent is entitled to judgment as a matter of law. We shall therefore grant respondent’s motion for summary judgment. To reflect the foregoing, An appropriate order and decision will be entered.Page: Previous 1 2 3 4 5 6 7 8 9 10 11
Last modified: May 25, 2011