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Section 6330(c) addresses the matters to be considered at
the hearing. As relevant here, a taxpayer may challenge the
appropriateness of the Commissioner's collection actions and
submit offers of collection alternatives. Sec. 6330(c)(2)(A)(ii)
and (iii). The taxpayer may also raise challenges to the
existence or amount of the underlying tax liability if the
taxpayer did not receive a statutory notice of deficiency for the
liability or did not otherwise have an opportunity to dispute the
tax liability. Sec. 6330(c)(2)(B).
Once the Appeals officer has issued a determination
regarding the disputed collection action, the taxpayer may seek
judicial review in the Tax Court or if the Tax Court lacks
jurisdiction in the matter, in a U.S. District Court. Sec.
6330(d). Where the validity of the underlying tax liability is
properly at issue, the Court will review the matter on a de novo
basis. However, where the validity of the underlying tax
liability is not properly at issue, the Court will review the
Commissioner's administrative determination for abuse of
discretion. Sego v. Commissioner, 114 T.C. 604, 610 (2000).
II. Analysis
In this case, petitioner's only challenge with respect to
the collection notice pertains to his underlying tax liabilities
for 1994, 1995, and 1996. Petitioner, however, was previously
issued statutory notices of deficiency for each of the years in
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