Estate of Nancy Sblendorio, Deceased, Michael F. Poppo, Executor - Page 9

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          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             

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Last modified: November 10, 2007