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dence] should be liquidated by either refinancing or
selling the property.
Balancing Efficient Collection with the
Instructiveness of Proposed Collection Actions
Although the tax liens are inherently intrusive, you
have proposed no other method of securing the govern-
ment’s interest. Therefore, the liens should remain on
file until the balances due in question are fully paid.
[Reproduced literally.]
OPINION
A taxpayer may raise challenges to the existence or the
amount of the taxpayer’s underlying tax liability if the taxpayer
did not receive a notice of deficiency or did not otherwise have
an opportunity to dispute such liability, sec. 6330(c)(2)(B),
including the tax liability reported in the return that such
taxpayer filed, Montgomery v. Commissioner, 122 T.C. 1 (2004).
Where the validity of the underlying tax liability is properly at
issue, the Court will review the matter on a de novo basis.
Where the validity of the underlying tax liability is not prop-
erly at issue, the Court will review the determinations of the
Commissioner of Internal Revenue for abuse of discretion. Sego v.
Commissioner, 114 T.C. 604, 610 (2000); Goza v. Commissioner, 114
T.C. 176, 181-182 (2000).
Before turning to the position of Ms. Latos in these cases,
it is important to bear in mind that Ms. Latos and respondent
stipulated that (1) it is only the unpaid assessed self-employ-
ment tax determined in the 1995 notice of deficiency (as well as
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