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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 excess
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