- 6 - 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 liability. 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.Page: Previous 1 2 3 4 5 6Last modified: November 10, 2007