Wyn Dee Stone - Page 7

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          delays by the IRS.  Respondent asserts that there was no abuse of           
          discretion in failing to abate statutory interest because                   
          petitioner did not identify the errors or delays.  Respondent               
          asserts that petitioner cannot challenge the addition to tax as             
          part of the underlying tax liability because petitioner received            
          a notice of deficiency and had a previous opportunity to contest            
          the tax.                                                                    
                                    Discussion                                       
               This Court has jurisdiction under section 6330 to review the           
          Commissioner’s administrative determinations.  Sec. 6330(d).                
          Section 6330(c)(2)(A) provides that the taxpayer may raise any              
          relevant issue with regard to the Commissioner’s collection                 
          activities, including spousal defenses, challenges to the                   
          appropriateness of the intended collection action, and                      
          alternative means of collection.  Additionally, the taxpayer may            
          challenge the existence or amount of the underlying tax                     
          liability, including a liability reported by the taxpayer on an             
          original return, if the taxpayer “did not receive any statutory             
          notice of deficiency for such tax liability or did not otherwise            
          have an opportunity to dispute such tax liability.”  Sec.                   
          6330(c)(2)(B); see also Montgomery v. Commissioner, 122 T.C. 1,             
          9-10 (2004).                                                                
               Petitioner’s underlying tax liability is not at issue                  
          because petitioner received a notice of deficiency on December 6,           






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