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be questioned, and we review respondent’s determination under an
abuse of discretion standard.
The main thrust of petitioner’s challenge concerns the
computations in the deficiency proceeding under Rule 155.
However, as noted, petitioner is not entitled to question the
underlying tax liabilities because he already has been provided
the opportunity to challenge his liabilities. See sec.
6330(c)(2)(B). In that regard, petitioner was provided with the
opportunity to submit a computation under Rule 155, but failed to
timely do so. Petitioner contends that Mr. Wall, his attorney,
did not submit a Rule 155 computation. Petitioner’s contention
with respect to his attorney’s failure does not change the
limitation upon petitioner or the Court with respect to
addressing the underlying merits of his 1993 or 1994 tax
liability. See sec. 6330(c)(2)(B).
With respect to petitioner’s second argument, concerning his
attempted offer-in-compromise, our review of the Commissioner’s
determination generally is limited to issues raised at the
section 6330 hearing. Magana v. Commissioner, 118 T.C. 488, 493
(2002). Petitioner’s offer-in-compromise was submitted after the
scheduled section 6330 hearing and the issuance of the final
notice. Accordingly, the offer-in-compromise could not have been
considered at the section 6330 hearing. There would, therefore,
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