- 9 - whether he was afforded a conference with Appeals. Accordingly, because Mr. Poppo had an opportunity to dispute the underlying tax liability in a conference with the Appeals Office, he may not raise that underlying liability again in a collection review hearing or before this Court. See sec. 6330(c)(2)(B); sec. 301.6320-1(e)(3), Q&A-E2, Proced. & Admin. Regs. Mr. Poppo has not raised in his petition any issues, other than the underlying liability, with respect to respondent’s proposed collection action. Therefore, for the reasons stated, respondent’s motion for summary judgment will be granted. To reflect the foregoing, An appropriate order and decision will be entered for respondent.Page: Previous 1 2 3 4 5 6 7 8 9Last modified: November 10, 2007