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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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