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raise any relevant issue with regard to the Commissioner’s
intended collection activities, including spousal defenses,
challenges to appropriateness of the collection action, and the
offers of collection alternatives. Sec. 6330(c); see Sego v.
Commissioner, 114 T.C. 604, 609 (2000); Goza v. Commissioner,
supra at 180-181.
Where the validity of the tax liability is not properly part
of the appeal, the Court reviews the determination of the Appeals
officer for abuse of discretion. Sego v. Commissioner, supra at
609-610; Goza v. Commissioner, supra at 181-182.
The taxpayer may raise challenges “to the existence or
amount of the underlying tax liability”, however, only if he “did
not receive any statutory notice of deficiency for such tax
liability or did not otherwise have an opportunity to dispute
such tax liability.” Sec. 6330(c)(2)(B).
Petitioner’s View of the Case
At trial, petitioner testified that Ms. Dellosso “violated
my due process rights by refusing to give me an opportunity to be
heard and have an accountant present so that we could present
appropriate collection alternatives.” Petitioner testified that
Ms. Dellosso was “impatient, abusive, capricious, argumentative,”
and did not properly consider her case. Petitioner asked that
Ms. Dellosso be “called to task” by the Court. Petitioner
testified that she wanted the Court to decide that her due
process rights had been violated by Ms. Dellosso.
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Last modified: May 25, 2011