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ties.14 In further support of her position that the Court should
not sustain the determinations at issue, Ms. Latos argues that
respondent abused respondent’s discretion in making those deter-
minations because the settlement officer did not “verify that all
applicable laws and procedures for the collection of employment
taxes have been met in accordance with I.R.C. § 6330(c)(1).”
(Emphasis added.)
In Anderson v. Commissioner, T.C. Memo. 2003-112, Ms. Latos
and Mr. Anderson filed a petition with the Court in response to a
notice of determination regarding a notice of intent to levy with
respect to their taxable years 1995 through 1997.15 Ms. Latos
and Mr. Anderson advanced in Anderson essentially the same
arguments that Ms. Latos advances in the instant cases.
In Anderson v. Commissioner, supra, the Court held that Ms.
Latos and Mr. Anderson were precluded under section 6330(c)(2)(B)
from challenging the underlying tax liability for their taxable
year 1995 because they (1) received a notice of deficiency for
that year in which respondent determined a deficiency in self-
employment tax and (2) failed to file a petition with the Court
14Ms. Latos does not contest the respective amounts of Ms.
Latos’ unpaid 1995, 1996, 1997, and 1998 liabilities.
15In the case at docket No. 5829-06L, Ms. Latos filed a
petition with the Court in response to the 1995 through 1997
notice of determination regarding a notice of tax lien with
respect to, inter alia, her taxable years 1995 through 1997.
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