Patricia Agnes Williams, Debbie Wales, Next Friend - Page 8

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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           
               Reviewed and adopted as the report of the Small Tax Case               
                                                  Decision will be entered            
          for respondent.                                                             

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