Randy R. Romano - Page 5

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          Court.  Section 6330(c)(2)(B) therefore precluded petitioner from           
          contesting his liability for the underlying taxes for those years           
          in the hearing.                                                             
               Because petitioner could not properly challenge the                    
          existence or amount of the underlying liability with respect to             
          the 1998, 1999, and 2000 tax years in the hearing, that issue is            
          not properly before this Court.  See Goza v. Commissioner, supra.           
          This Court will review respondent’s determination with respect to           
          the 1998, 1999, and 2000 tax years for abuse of discretion.                 
               Petitioner failed to assert any of the claims enumerated               
          under section 6330(c)(2)(A) in the hearing.  In particular,                 
          petitioner did not challenge the appropriateness of the intended            
          method of collection or offer a collection alternative, or raise            
          any such issue before the Court.  Consequently, there is no                 
          dispute as to material fact with respect to the 1998, 1999, and             
          2000 tax years.  Accordingly, we find no abuse of discretion in             
          respondent’s determination.                                                 
               Petitioner did not receive a notice of deficiency for tax              
          year 2001 or have an opportunity to dispute that liability before           
          the hearing.  To the extent petitioner is attempting to challenge           
          the underlying Federal income tax liability for the 2001 tax                
          year, that challenge is appropriate, even though the liability              
          was self-reported.  See Montgomery v. Commissioner, 122 T.C. 1              
          (2004).                                                                     
               Rule 331(b)(4) states that a petition for review of an                 




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