Denis J. Faris and Carolyn M. Faris - Page 6

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                                       OPINION                                        
          I.  Determination To Proceed With Collection                                
               Section 6330(a) provides that the Secretary shall furnish              
          taxpayers with written notice of their right to a hearing before            
          any property is levied upon.  Section 6330 further provides that            
          the taxpayer may request administrative review of the matter (in            
          the form of a hearing) within a prescribed 30-day period.  Sec.             
          6330(a) and (b).                                                            
               Pursuant to section 6330(c)(2)(A), a taxpayer may raise at             
          the section 6330 hearing any relevant issue with regard to the              
          Commissioner’s collection activities, including spousal defenses,           
          challenges to the appropriateness of the Commissioner’s intended            
          collection action, and alternative means of collection.  Sego v.            
          Commissioner, 114 T.C. 604, 609 (2000); Goza v. Commissioner, 114           
          T.C. 176, 180 (2000). If a taxpayer received a statutory notice             
          of deficiency for the year in issue or otherwise had the                    
          opportunity to dispute the underlying tax liability, the taxpayer           
          is precluded from challenging the existence or amount of the                
          underlying tax liability.  Sec. 6330(c)(2)(B); Sego v.                      
          Commissioner, supra at 610-611; Goza v. Commissioner, supra at              
          182-183.                                                                    
               Aside from raising frivolous arguments regarding the                   
          validity of the notices they received, petitioners admit that               
          they received notices of deficiency for 1997 and 1998.  Thus,               






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