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tax liability. Sec. 6330(c)(2)(B);5 Sego v. Commissioner, 114
T.C. 604, 610 (2000).
In the instant case, petitioners received a statutory notice
of deficiency. Consequently, section 6330(c)(2)(B) precluded
petitioners from challenging the underlying tax liability at the
section 6330 hearing. Accordingly, we review the administrative
determination for abuse of discretion. See Goza v. Commissioner,
114 T.C. 176, 181-182 (2000); Sego v. Commissioner, supra at 610.
The record establishes that the Appeals Office properly
verified that all applicable laws and administrative procedures
were followed. Appeals Officer Johnson had no prior involvement
with respect to the unpaid tax liabilities before the section
6330 hearing. The Form 4340 shows that proper assessments were
made and that requisite notices had been sent to petitioners.
Petitioners raised no viable claims of procedural
irregularities,6 and respondent properly relied on the Form 4340
during the administrative process. See Nestor v. Commissioner,
supra. Petitioners did not discuss collection alternatives.
5Sec. 6330(c)(2)(B) provides:
(B) Underlying liability.--The person may also raise at
the hearing challenges to the existence or amount of the
underlying tax liability for any tax period if the person
did not receive any statutory notice of deficiency for such
tax liability or did not otherwise have an opportunity to
dispute such tax liability.
6We address respondent’s refusal to allow the recording of
sec. 6330 hearings below.
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