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issue relating to the unpaid tax, including appropriate spousal
defenses, challenges to the appropriateness of collection
actions, and offers of collection alternatives. Section
6330(c)(2)(B) provides that the person may also raise at the
hearing challenges to the existence or amount of the underlying
tax liability if the person did not receive a statutory notice of
deficiency for such tax liability or did not otherwise have an
opportunity to dispute such tax liability.
Section 6330(d) provides for judicial review of the
administrative determination in the Tax Court or a Federal
District Court, as may be appropriate.
Petitioner asserts that the Appeals Office erred in denying
her an opportunity to challenge her underlying liabilities for
1995 and 1996 because (1) she did not receive a notice of
deficiency for those years, and (2) she was never given a full
and fair opportunity to contest her liability for additions to
tax for fraud for those years. We disagree.
As previously discussed, section 6330(c)(2)(B) provides that
the person may raise at the hearing challenges to the existence
or amount of the underlying tax liability if the person did not
receive a statutory notice of deficiency for such tax liability
or did not otherwise have an opportunity to dispute such tax
liability. The record in this case reflects that, although
petitioner did not receive a statutory notice of deficiency for
1995 and 1996, she did in fact have a prior opportunity to
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