- 10 - warrant further consideration of the merits of its case by the Appeals Office or this Court. Petitioner focused its argument on the fact that it was not provided a face-to-face hearing, nor Form 4340 with a 23C date prior to the issuance of the notice of determination, as requested. The Court concludes that all pertinent issues relating to the underlying corporate tax liability and the propriety of the collection determination can be decided based on the present record. III. Standard of Review At issue in this case is respondent’s right to collect petitioner’s self-determined tax liability for 2000 (i.e., the amount set forth on petitioner’s filed 2000 Form 1120-X). A taxpayer’s challenge to his self-determined tax liability at an Appeals Office hearing constitutes a permissible challenge to the underlying tax liability under section 6330(c)(2)(B). Montgomery v. Commissioner, 122 T.C. 1, 9 (2004). Petitioner contends that this Court should review the instant case de novo, stating: “The Petitioner filed the 1120 tax return and self-assessed the tax without any judicial determination.” However, petitioner is not disputing the accuracy of its self-determined tax liability. See supra note 4. Instead, petitioner argues that it should have had a face-to-face hearing, with which the Court has already indicated its disagreement, and, as discussed and addressedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007