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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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