Ronald Lee Snyder - Page 13

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          timely filed with the IRS with respect to the notice of intent to           
          levy.  Respondent concedes that the decision letter that the                
          Appeals Office issued to petitioner with respect to that notice             
          constitutes a “determination” for purposes of section 6330(d)(1).           
          We agree with respondent’s concession.  Craig v. Commissioner,              
          119 T.C. 252, 259 (2002).  We conclude that the determination               
          reflected in the decision letter coupled with petitioner’s timely           
          filed petition with the Court with respect to, inter alia, that             
          determination invokes the Court’s jurisdiction under section                
          6330(d)(1).  Moorhous v. Commissioner, 116 T.C. 263, 269 (2001).            
               We turn now to the determinations with respect to the notice           
          of tax lien and the notice of intent to levy relating to peti-              
          tioner’s taxable years 1994, 1996, 1998, and 1999.  A taxpayer              
          may raise challenges to the existence or the amount of the                  
          taxpayer’s underlying liability if the taxpayer did not receive a           
          notice of deficiency or did not otherwise have an opportunity to            
          dispute the tax liability.  Sec. 6330(c)(2)(B).  Where the                  
          validity of the underlying tax liability is properly placed at              
          issue, the Court will review the matter on a de novo basis.  Sego           
          v. Commissioner, 114 T.C. 604, 610 (2000); Goza v. Commissioner,            
          114 T.C. 176, 181-182 (2000).                                               
               With respect to petitioner’s taxable years 1994 and 1996,              
          respondent based the assessment with respect to each of those               
          years on the tax shown in petitioner’s return for each such year.           






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