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of Appeals) and, if dissatisfied, with judicial review of the
administrative determination. See Davis v. Commissioner, 115
T.C. 35, 37 (2000); Goza v. Commissioner, 114 T.C. 176, 179
(2000).
Section 6330(c)(1) imposes an obligation on the Appeals
Office to obtain verification that the requirements of any
applicable law or administrative procedure have been met in each
case. Section 6330(c)(2) prescribes the matters that a person
may raise during the administrative process. In sum, section
6330(c)(2) provides that a person may raise collection issues
such as spousal defenses, the appropriateness of the
Commissioner's intended collection action, and possible
alternative means of collection. Section 6330(c)(2)(B) provides
that the existence and amount of the underlying tax liability can
be contested only if the person did not receive a notice of
deficiency for the taxes in question or did not otherwise have an
earlier opportunity to dispute the tax liability. See Sego v.
Commissioner, 114 T.C. 604, 609 (2000); Goza v. Commissioner,
supra.
The record reflects that petitioner received the deficiency
notices for 1998 and 1999 yet petitioner consciously decided not
to file a petition for redetermination with the Court.
Consistent with section 6330(c)(2)(B), petitioner is barred from
challenging the existence or amount of his underlying tax
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