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granting taxpayers a right to contest the existence or
amount of an underlying tax liability, Congress was
concerned with tax liabilities asserted by respondent,
rather than those originally computed and reported by
the taxpayers themselves. This concern is evident in
the phrasing of section 6330(c)(2)(B), which permits a
taxpayer to contest an underlying tax liability in the
event that he or she has been denied a prior
opportunity to contest that liability in the form of a
“statutory notice of deficiency” or “otherwise.” It is
nonsensical to permit taxpayers whose tax liabilities
are self-determined to contest under section 6330 the
liabilities they computed, voluntarily reported and
declared to be correct under penalty of perjury.
Respondent further asserts that there is no suggestion in the
legislative history underlying section 6330 that Congress
intended to permit taxpayers to challenge taxes that were “self-
assessed” on a tax return. Finally, respondent maintains that,
inasmuch as section 6330 constitutes a waiver of sovereign
immunity, the provision should be narrowly construed in the
Commissioner’s favor.
Before proceeding, we briefly review the principles of
statutory construction that guide our analysis. It is well
settled that in interpreting a statute, we start with the
language of the statute itself. Consumer Prod. Safety Commn. v.
GTE Sylvania, Inc., 447 U.S. 102, 108 (1980). If the language of
the statute is plain, clear, and unambiguous, we generally apply
it according to its terms. United States v. Ron Pair Enters.,
Inc., 489 U.S. 235, 241 (1989); Burke v. Commissioner, 105 T.C.
41, 59 (1995). In Huntsberry v. Commissioner, 83 T.C. 742, 747-
748 (1984), we stated that “where a statute is clear on its face,
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