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          II.  Section 301.6330-1(e), Proced. & Admin. Regs.                          
               Before proceeding, it is necessary to comment on the                   
          majority’s disposition of section 301.6330-1(e), Proced. & Admin.           
          Regs., set forth in pertinent part on page 9 of the majority’s              
          opinion.  Subsection (e)(1) of that regulation states quite                 
          clearly that, at a section 6330 (Collection Due Process (CDP)               
          hearing), the taxpayer “may raise challenges to the existence or            
          amount of the tax liability specified on the CDP Notice * * * if            
          the taxpayer did not receive a statutory notice of deficiency for           
          that tax liability or did not otherwise have an opportunity to              
          dispute that tax liability.”  (Emphasis added.)  See also                   
          subsection (e)(3), Q&A-E2 (similar).2  The pertinent language of            
          subsection (e)(1) of the regulation is essentially the same as              
          the language of section 6330(c)(2)(B) except that, in the                   
          regulation, the term “tax liability specified on the CDP Notice”            
          is substituted for the term “underlying tax liability”.  Thus,              
          the drafters of the regulation fixed the meaning of the term                
          “underlying tax liability” as “the tax liability specified on the           
          CDP Notice”.                                                                
               As the majority recites, on March 19, 2002, respondent                 
          issued to petitioners a final notice (CDP notice) stating that              
          petitioners owed tax, penalties, and interest (for 2002) totaling           
               2  Sec. 301.6320-1(e)(1), (3), Q&A-E2, Proced. & Admin.                
          Regs., is similar but relates to liens rather than levies.                  
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