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violate the PRA); United States v. Neff, 954 F.2d 698, 699 (11th
Cir. 1992) (lack of an OMB number on a Federal income tax
regulation does not violate the PRA); Freas v. Commissioner, T.C.
Memo. 1993-552 (PRA does not apply to Federal income tax
regulations or to Federal tax forms); Andreas v. Commissioner,
T.C. Memo. 1993-551 (similar to Freas v. Commissioner, supra).
We find petitioner received a valid statutory notice of
deficiency, and thus his underlying tax liability is not properly
at issue. See sec. 6330(c)(2)(B). Accordingly, we review
respondent’s notice of determination for an abuse of discretion.
See Sego v. Commissioner, supra at 610; Goza v. Commissioner,
supra at 181-182.
Petitioner asks the Court to find that respondent abused his
discretion by issuing the notice of determination. Petitioner
advances three primary arguments: (1) Respondent did not make a
valid assessment; (2) respondent improperly barred petitioner
from recording the telephonic section 6330 hearing; and (3)
respondent erred in rejecting petitioner’s collection
alternative.
Petitioner first claims that respondent did not make a valid
assessment. In making this assertion, petitioner advances
several tax protester-type arguments, including: No Code section
makes him liable to pay tax; respondent’s settlement officer was
not the Secretary of the Treasury, nor was authority properly
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