Patricia Agnes Williams, Debbie Wales, Next Friend - Page 6

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          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).                                                                     
               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 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).                                   
               At trial, petitioner’s only argument was that she did not              
          receive the statutory notice of deficiency for the underlying tax           
          liability and that the IRS could not prove that they had sent it.           
          Therefore, she argues, the assessment in this case is wrongful.             
          In making this argument, petitioner attempts to challenge “the              
          existence or amount of the underlying tax liability”, which is              
          allowed under the law only if she “did not receive any statutory            
          notice of deficiency for such tax liability or did not otherwise            






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