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within the 90-day period prescribed by section 6312. Because
petitioner had an opportunity to contest his income tax liability
and failed to do so, section 6330(c)(2)(B) precluded petitioner
from questioning that underlying liability at his section 6330
hearing. See Goza v. Commissioner, supra at 182-183 (“Although
* * * [the taxpayer] received a notice of deficiency * * * he did
not avail himself of the opportunity to file a petition for
redetermination with the Court pursuant to section 6213(a).
Consistent with section 6330(c)(2)(B), * * * [the taxpayer]
therefore was precluded from contesting his liability for the
underlying taxes before the Appeals Office.”). As petitioner’s
underlying tax liability was not properly at issue in the section
6330 hearing, we hold that the validity of the underlying tax
liability is not properly before this Court. See Sego v.
Commissioner, supra at 611.
Petitioner failed to raise any other relevant issues or
challenges in the petition. Pursuant to Rule 331(b)(4), all
other issues are deemed conceded.
The decision in this case will indicate that we sustain
respondent’s administrative determination to proceed with
collection against petitioner. Our decision does not serve as a
review of respondent’s determination as to petitioner’s
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