Keith M. Felder - Page 7

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          “compensation” were erroneously reported as wages.                          
               Because petitioner received a statutory notice of deficiency           
          for the year for which collection is at issue here, he may not              
          raise his frivolous challenges to the existence or amount of the            
          underlying tax liability.  Sec. 6330(c)(2)(B).  Petitioner did              
          not raise any permitted argument with respect to spousal                    
          defenses, challenges to the appropriateness of the Commissioner’s           
          intended collection action, or alternative means of collection.             
                                     Conclusion                                       
               Respondent’s determination to proceed with collection action           
          was not an abuse of his discretion.                                         
               Reviewed and adopted as the report of the Small Tax Case               
          Division.                                                                   
               To reflect the foregoing.                                              
                                                  Decision will be entered            
                                             for respondent.                          
                                                                                     

















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