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6330(c)(2)(A). The taxpayer also may raise challenges to the
existence or amount of the underlying tax liability at a hearing
if the taxpayer did not receive a statutory notice of deficiency
with respect to the underlying tax liability or did not otherwise
have an opportunity to dispute that liability. Sec.
6330(c)(2)(B); Montgomery v. Commissioner, 122 T.C. 1 (2004).
This Court has jurisdiction under section 6330 to review the
Commissioner’s administrative determinations. Sec. 6330(d);
Iannone v. Commissioner, 122 T.C. 287, 290 (2004). Where, as
here, the validity of the underlying tax liability is not at
issue, we review the determination for abuse of discretion. Sego
v. Commissioner, 114 T.C. 604, 610 (2000); Goza v. Commissioner,
114 T.C. 176, 182 (2000). Whether an abuse of discretion has
occurred depends upon whether the exercise of discretion is
without sound basis in fact or law. See Freije v. Commissioner,
125 T.C. 14, 23 (2005). The Commissioner’s refusal to consider
collection alternatives is not an abuse of discretion where the
taxpayer has failed to file all required tax returns or to
provide complete financial information. See Roman v.
Commissioner, T.C. Memo. 2004-20; Rodriguez v. Commissioner, T.C.
Memo. 2003-153 (and cases cited therein).
Petitioner contends she sent the requested information to
respondent on November 28, 2005. Petitioner testified that she
did not send the information by certified or registered mail,
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