Early Robertson, Jr. - Page 8

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               determination for abuse of discretion. [Sego v.                        
               Commissioner, 114 T.C. 604, 610 (2000).]                               
          II.  Contentions of the Parties                                             
               Although less than entirely clear, petitioner’s petition and           
          amended petition appear to contest respondent’s collection                  
          determination on the basis of a challenge to his underlying                 
          liabilities for some or all of the years from 1993 to 1999.  The            
          pleadings filed suggest that petitioner believes he is entitled             
          to an additional dependent exemption deduction and head of                  
          household filing status.  Conversely, neither of these documents            
          seems to raise issues related to spousal defenses, collection               
          alternatives, or other challenges to the appropriateness of the             
          collection action.  At the hearing on respondent’s motion,                  
          petitioner did raise an installment agreement and 22 $65 payments           
          thereon, totaling $1,430, all of which were applied to his 1995             
          tax year.                                                                   
               Respondent’s motion seeks summary judgment with respect to             
          the 1995 to 1999 period covered in the notice of determination.             
          As pertains to that period, the motion is premised on two                   
          principal considerations, each of which addresses petitioner’s              
          attempts to dispute his underlying tax liabilities.  First,                 
          respondent maintains that because petitioner received a notice of           
          deficiency for 1995 and 1996, he is precluded from challenging              
          his underlying liabilities as to those years.  Second, it is                
          respondent’s position that petitioner may not challenge his                 

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