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conclude that there are no genuine issues of material fact
regarding the questions raised in respondent’s motion for summary
judgment.
A taxpayer may raise challenges to the existence or the
amount of the taxpayer’s underlying liability if the taxpayer did
not receive a notice of deficiency or did not otherwise have an
opportunity to dispute the tax liability. Sec. 6330(c)(2)(B).
Where the validity of the underlying tax liability is properly
placed at issue, the Court will review the matter on a de novo
basis. Sego v. Commissioner, 114 T.C. 604, 610 (2000); Goza v.
Commissioner, 114 T.C. 176, 181-182 (2000).
We turn first to petitioner’s taxable years 1980 through
1984. Respondent issued a notice of deficiency to petitioner
with respect to those years. Petitioner filed a petition with
the Court with respect to that notice. On September 20, 1990,
the Court entered a decision in petitioner’s Tax Court case.
That decision stated, inter alia, that there was a deficiency in
petitioner’s tax for each of his taxable years 1980 through 1984
and that there were certain additions to such tax for each such
year except 1980.9
9The IRS filed a proof of claim with respect to, inter alia,
petitioner’s taxable years 1980 through 1984. In addition to
petitioner’s having had the opportunity to dispute the determina-
tions in the notice of deficiency that respondent issued to him
with respect to his taxable years 1980 through 1984, which he did
in petitioner’s Tax Court case, as discussed below, petitioner
was afforded an opportunity to dispute the underlying tax liabil-
(continued...)
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