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We have jurisdiction to review respondent’s determination of
the validity of the Federal tax lien on petitioner’s property
under section 6320. See secs. 6211(a), 6213(a), 6214(a); Parker
v. Commissioner, 117 T.C. 63, 65 (2001); Van Es v. Commissioner,
115 T.C. 324, 327 (2000).
Where the validity of the underlying tax liability is
properly at issue, the Court will review the matter de novo.
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. Goza v.
Commissioner, 114 T.C. 176, 181-182 (2000). A taxpayer’s
underlying tax liability may be at issue if he did not receive
any statutory notice of deficiency for such tax liability or did
not otherwise have an opportunity to dispute such tax liability.
See secs. 6320(c), 6330(c)(2)(B).
Petitioner claims he did not file petitions with this Court
contesting the determinations in the three notices of deficiency
because he did not receive the notices of deficiency.
The notices of deficiency were properly mailed on December
12, 1996, to petitioner’s last known address, which, at the time,
8(...continued)
review them. See Internal Revenue Service Restructuring and
Reform Act of 1998, Pub. L. 105-206, sec. 3401, 112 Stat. 746
(which created new sec. 6330 and provided for an effective date
of 180 days after July 22, 1998); see also Van Es v.
Commissioner, 115 T.C. 324, 327-328 (2000).
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