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Appeals and, if necessary, to file a petition with the Tax Court
to contest the issue, she is precluded from now attacking the
assessment. Bell v. Commissioner, 126 T.C. 356 (2006).
The only issue raised by petitioner addressed the existence
of the underlying tax liability, which issue the Court has
determined she is precluded from raising. The Court finds,
therefore, that respondent did not abuse his discretion in
determining that the filing of the Notice of Federal Tax Lien was
appropriate.
Reviewed and adopted as the report of the Small Tax Case
Division.
Decision will be entered
for respondent.
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Last modified: May 25, 2011