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underlying tax liability. Van Es v. Commissioner, 115 T.C. 324,
328 (2000).
Although section 6330 does not prescribe the standard of
review that the Court is to apply in reviewing the Commissioner’s
administrative determinations, we have stated that, where the
validity of the underlying tax liability is properly at issue,
the Court will review the matter de novo. Sego v. Commissioner,
114 T.C. 604, 610 (2000); Goza v. Commissioner, 114 T.C. 176, 181
(2000). Where the validity of the underlying tax liability is
not properly at issue, however, the Court will review the
Commissioner’s administrative determination for abuse of
discretion. Sego v. Commissioner, supra; Goza v. Commissioner,
supra.
The notice of deficiency for the year 2000 was sent to
petitioner’s last known address. Petitioner does not dispute
that he received the notice of deficiency for 2000. Accordingly,
he cannot challenge his underlying liability. See sec.
6330(c)(2)(B); Sego v. Commissioner, supra at 610-611; Goza v.
Commissioner, supra at 182-183. Therefore, we review
respondent’s determination for an abuse of discretion. See Sego
v. Commissioner, supra at 610.
Petitioner has failed to raise a spousal defense, make a
valid challenge to the appropriateness of respondent’s intended
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