Fred Deutsch - Page 15

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         See, e.g., Willoughby v. Commissioner, supra; 1 Restatement,                 
         Agency 2d, secs. 112 comment C, 165 (1958).  Accordingly, the                
         waivers are valid, and the assessment of the tax was proper.                 
              Under the circumstances, petitioner is deemed to have had a             
         prior opportunity to dispute his liabilities for 1995, 1996, and             
         1997 within the meaning of section 6330(c)(2)(B).  Consequently,             
         petitioner is not entitled to challenge the existence or amount              
         of his 1995, 1996, and 1997 tax liabilities during the collection            
         review process.  See Zapara v. Commissioner, 124 T.C. at 228;                
         Aguirre v. Commissioner, 117 T.C. at 327.                                    
              To reflect the foregoing,                                               

                                            An order granting respondent’s            
                                       motion for partial summary judgment            
                                       will be issued.                                






















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