John J. Delgado - Page 8

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               Pursuant to section 6330(c)(2)(A), a taxpayer may raise at             
          the section 6330 hearing any relevant issue with regard to the              
          Commissioner’s collection activities, including spousal defenses,           
          challenges to the appropriateness of the Commissioner’s intended            
          collection action, and alternative means of collection.  Id. at             
          609; Goza v. Commissioner, supra at 180.  If a taxpayer received            
          a statutory notice of deficiency for the years in issue or                  
          otherwise had the opportunity to dispute the underlying tax                 
          liability, the taxpayer is precluded from challenging the                   
          existence or amount of the underlying tax liability.  Sec.                  
          6330(c)(2)(B); Sego v. Commissioner, supra at 610-611; Goza v.              
          Commissioner, supra at 182-183.                                             
               A section 6330 hearing “may, but is not required to, consist           
          of a face-to-face meeting.”  Sec. 301.6330-1(d)(2), Q&A-D6,                 
          Proced. & Admin. Regs.  If a taxpayer wants a face-to-face                  
          section 6330 hearing, the taxpayer must be offered an opportunity           
          for such a section 6330 hearing at the Appeals office closest to            
          the taxpayer’s residence.  Sec. 301.6330-1(d)(2), Q&A-D7, Proced.           
          & Admin. Regs.                                                              
               Although respondent denied petitioner a face-to-face section           
          6330 hearing and the right to record the section 6330 hearing, we           
          conclude that it is not necessary and will not be productive to             
          remand this case to the Appeals Office for a face-to-face section           
          6330 hearing in order to allow petitioner to make his frivolous             

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