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issuing the determination, not that he or she provide it to the
taxpayer. Further, there is no legal requirement that the
Appeals officer provide a taxpayer with copies of the delegations
of authority, assessment records, or other underlying documents
maintained by respondent with respect to a taxpayer’s account.
Nestor v. Commissioner, supra at 166. Accordingly, the Appeals
officer in this case sufficiently verified the 2001 tax
assessments and was not required to provide more.
The 2001 Tax Liability
A taxpayer may challenge the existence or amount of the
underlying tax, however, only if he did not receive any statutory
notice of deficiency for the tax liability or did not otherwise
have an opportunity to dispute the tax liability. Sec.
6330(c)(2)(B). Where the validity of the underlying tax
liability is properly in issue, the Court will review the matter
de novo. Where the validity of the underlying tax is not
properly in issue, however, the Court will review the
Commissioner's administrative determination for abuse of
discretion. Sego v. Commissioner, 114 T.C. 604, 610 (2000); Goza
v. Commissioner, 114 T.C. at 181-182.
In this case petitioner was not entitled to contest the
underlying tax liability for 2001, the only year that this Court
has jurisdiction to consider. Even if petitioner had been
entitled to contest the underlying tax liability, other than
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