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administrative determination for an abuse of discretion. Sego v.
Commissioner, 114 T.C. 604, 610 (2000); Goza v. Commissioner, 114
TC 176, 181-182 (2000).
Although petitioner received a statutory notice of
deficiency for the taxable year 2001, he did not avail himself of
the opportunity to file a petition for redetermination of the
deficiency with this Court pursuant to section 6213(a).
Consistent with section 6330(c)(2)(B), petitioner therefore was
precluded from contesting his liability for the underlying taxes
before the Appeals Office. Goza v. Commissioner, supra at 182-
183. Therefore, the validity of petitioner's underlying tax
liability is not properly at issue in this proceeding. Id. at
183.
Nevertheless, petitioner continues to assert frivolous
claims. See, e.g., Pond v. Commissioner, T.C. Memo. 2005-255
(rejecting taxpayer’s argument that exemption amount is not
defined by statute); Saxon v. Commissioner, T.C. Memo. 2006-52
(taxpayer’s contention that OMB control No. 1545-0074, on the
Form 1040 is invalid and does not comply with the requirements of
the PRA is groundless (citing James v. United States, 970 F.2d
750, 753 n.6 (10th Cir. 1992); United States v. Neff, 954 F.2d
698, 699 (11th Cir. 1992)). Petitioner does not challenge the
appropriateness nor the intended method of collection. Nor does
petitioner offer any alternative means of collection or raise any
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