- 11 - supra at 610. The Court reviews all other administrative determinations for abuse of discretion. Id. I. Petitioner’s Challenge to the Underlying Tax Liabilities Section 6330(c)(2)(B) provides that a taxpayer may dispute the existence or amount of his unpaid tax liability if he did not receive a notice of deficiency or otherwise have an opportunity to dispute such tax liability. The “opportunity to dispute such tax liability” includes a conference with the Appeals Office that was offered either before or after the tax liability was assessed. Sec. 301.6320-1(e)(3), Q&A-E2, Proced. & Admin. Regs. Most of petitioner’s arguments are directed to collection alternatives and do not raise challenges to the underlying tax liabilities for 2000 and 2001. However, during the administrative proceeding, petitioner inquired about the possibility of offsetting his unpaid liabilities with the AMT that he had paid. The record contains no evidence that the settlement officer specifically answered his inquiry. In this proceeding, petitioner has again raised the question of whether he can reduce his unpaid tax liabilities by the amount of AMT he paid. Although his argument is very unclear, we interpret it as an assertion that he is entitled to a credit under section 53. Section 53 authorizes a taxpayer to claim a credit for net minimum tax paid in prior years, adjusted for specified items. The minimum tax credit allowable under section 53 is the excessPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008