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The only issue that petitioner appears to raise in the
petition in this case is the underlying tax liability for peti-
tioner’s taxable years 1995, 1996, 1997, 1999, and 2000. In the
petition, petitioner alleges:
I was under tremendous stress and medical conditions
that did not allow me to function normally in the daily
life. As soon as I became capable of living my normal
life I addressed the issues that burdened me during
that time. [Reproduced literally.]
Respondent issued a notice of deficiency to petitioner with
respect to his taxable years 1995, 1996, 1997, 1999, and 2000,
but petitioner did not file a petition with the Court with
respect to that notice. On the instant record, we find that
petitioner may not challenge the existence or the amount of
petitioner’s unpaid liabilities for 1995, 1996, 1997, 1999, and
2000. See sec. 6330(c)(2)(B); Sego v. Commissioner, 114 T.C.
604, 610-611 (2000); Goza v. Commissioner, 114 T.C. 176, 182-183
(2000).
Where, as is the case here, the validity of the underlying
tax liability is not properly placed at issue, the Court will
review the determination of the Commissioner of Internal Revenue
for abuse of discretion. Sego v. Commissioner, supra at 610;
Goza v. Commissioner, supra at 182.
Based upon our examination of the entire record before us,
we find that respondent did not abuse respondent’s discretion in
making the determinations in the notice of determination with
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