Carol L. Van Dyke - Page 5

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          Goza v. Commissioner, 114 T.C. 176, 180 (2000).  In addition,               
          section 6330(c)(2)(B) establishes the circumstances under which a           
          person may challenge the existence or amount of her underlying              
          tax liability.  Section 6330(c)(2)(B) provides that the person              
          may raise at the hearing challenges to the existence or amount of           
          the underlying tax liability if the person did not receive a                
          statutory notice of deficiency for the tax liability or did not             
          otherwise have an opportunity to dispute the liability.                     
               Petitioner submitted at trial an eight-page handwritten                
          document that she testified was a summary of her case.  The                 
          document, rambling and difficult to follow, repeats some                    
          allegations from the petition and raises new matter.  The new               
          matter includes allegations that an IRS employee stole her car,             
          that President Bush made lewd comments to her by telephone, and             
          that Archibald Cox stole from her a "Red Samsonite suitcase".               
          The evidence she submitted includes a handwritten document for              
          tax year 1995 listing a $6,900 deduction for a 1983 van that she            
          alleges was stolen from her "By President Clinton".                         
               Petitioner has alleged that certain correspondence,                    
          including the notice of deficiency for 1992, was sent to her                
          using, in whole or in part, her maiden name.  She alleges that              
          her maiden name is "not my name".  She has, however, not denied             
          receiving notices of deficiency for 1992 and 2000.  The Court               
          concludes that petitioner is precluded from challenging the                 






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