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(2002). The party opposing summary judgment must set forth
specific facts which show that a question of genuine material
fact exists and may not rely merely on allegations or denials in
the pleadings. See Grant Creek Water Works, Ltd. v.
Commissioner, 91 T.C. 322, 325 (1988); Casanova Co. v.
Commissioner, 87 T.C. 214, 217 (1986).
Section 6330(c)(2)(A) prescribes issues that may be raised
by a taxpayer in a section 6330 hearing, including spousal
defenses to collection, challenges to the appropriateness of the
Commissioner’s intended collection action, and offers of
collection alternatives. Unless the taxpayer did not receive a
notice of deficiency for the taxes in question or did not
otherwise have an opportunity to dispute the tax liability, the
section 6330 hearing is not a forum to contest the existence or
amount of the underlying taxes. Sec. 6330(c)(2)(B).
Where the validity of the underlying tax liability is
properly in issue, the Court will review the matter de novo.
However, where the validity of the underlying tax liability is
not properly in issue, the Court will review the Commissioner’s
administrative determination for abuse of discretion. Sego v.
Commissioner, 114 T.C. 604, 610 (2000); Goza v. Commissioner, 114
T.C. 176, 181-182 (2000).
Although petitioner received a notice of deficiency for the
1998, 1999, and 2000 tax years, he did not avail himself of the
opportunity to file a petition for redetermination with the
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