-4-
underlying tax liability de novo. See Sego v. Commissioner,
114 T.C. 604, 610 (2000); Hoffman v. Commissioner, 119 T.C. 140,
144-145 (2002).
Petitioner raises no valid legal arguments. She argues, in
both her request for a hearing and in her petition to this Court,
that she does not owe any tax for 1996. This she may not do.
Petitioner, having received a notice of deficiency and having
forgone the opportunity to challenge her underlying liability in
her prior case, is barred from doing so in this case. See sec.
6330(c)(2)(B); Ginalski v. Commissioner, T.C. Memo. 2004-104.
C. Conclusion
We shall grant respondent’s motion for summary judgment.
To reflect the foregoing,
An appropriate order and
decision will be entered for
respondent.
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Last modified: May 25, 2011