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regard to the Commissioner’s intended collection activities,
including spousal defenses, challenges to the appropriateness of
the Commissioner’s intended collection action, and alternative
means of collection. Secs. 6320(b) and (c), 6330(c); see Sego v.
Commissioner, 114 T.C. 604, 609 (2000); Goza v. Commissioner, 114
T.C. 176, 180 (2000).
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).
Where the validity of the tax liability is not properly part
of the appeal, the taxpayer may challenge 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 only issues raised by petitioner at the section 6330
hearing were: (1) That petitioner did not understand the nature
of the decision document he signed in his deficiency proceeding
for 1997 in this Court;1 and (2) whether petitioner’s tax
liability for 1997 was discharged in bankruptcy. At trial,
1Because petitioner did not pursue the issue at trial, the
Court considers petitioner to have conceded the issue of his
unilateral mistake. Bradley v. Commissioner, 100 T.C. 367, 370
(1993); Sunstrand Corp. v. Commissioner, 96 T.C. 226, 344 (1991);
Rybak v. Commissioner, 91 T.C. 524, 566 n.19 (1988).
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