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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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