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(B) Underlying liability.–-The person may also
raise at the hearing challenges to the existence or
amount of the underlying tax liability for any tax
period if the person did not receive any statutory
notice of deficiency for such tax liability or did not
otherwise have an opportunity to dispute such tax
liability.
In his petition, petitioner challenges his underlying 1993
tax liability. Because petitioner received a notice of
deficiency for the 1993 tax year and failed to file a petition in
this Court, he is not entitled to challenge the existence or
amount of his underlying 1993 tax liability in this collection
proceeding. See secs. 6320(c), 6330(c)(2)(B); Sego v.
Commissioner, 114 T.C. 604, 609 (2000); Goza v. Commissioner, 114
T.C. 176, 180-181 (2000). Where the validity of the tax
liability is not properly at issue, the Court will review the
Commissioner's administrative determination for abuse of
discretion. Sego v. Commissioner, supra at 610; Goza v.
Commissioner, supra at 182.
Petitioner contends that the Appeals officer abused his
discretion by failing to offer or discuss an offer in compromise
or an installment agreement. Section 6330 contemplates, however,
that it is the taxpayer who will raise at the hearing relevant
issues, including offers of collection alternatives. Sec.
6330(c)(2)(A)(iii). The statute requires the Appeals officer
only to consider the "offers of collection alternatives" raised
and information presented by the taxpayer. Chandler v.
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