Edward G. Castleman - Page 6

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          constitutes an opportunity to dispute the underlying tax                    
          liability, sec. 6330(c)(2)(B), as does the receipt of a notice of           
          intent to levy, Miller v. Commissioner, T.C. Memo. 2007-35; sec.            
          301.6320-1(e)(3), A-E7, Proced. & Admin. Regs.; see also Bell v.            
          Commissioner, 126 T.C. 356 (2006).  This is true even if the                
          taxpayer did not request an administrative hearing in response to           
          the notice of intent to levy.  See Miller v. Commissioner, supra;           
          sec. 301.6320-1(e)(3), A-E7, Proced. & Admin. Regs.  Accordingly,           
          petitioner is precluded from challenging the underlying tax                 
               On the basis of our review of the record, we conclude that             
          respondent satisfied the requirements of section 6330(c) and did            
          not abuse his discretion in sustaining the notice of Federal tax            
          lien filed against petitioner.  Respondent’s determination                  
          therefore is sustained.                                                     
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for respondent.                          

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