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otherwise have an opportunity to dispute such
tax liability.
Petitioner’s liabilities were self-reported and arguably the
subject of challenge at the hearing. See Montgomery v.
Commissioner, 122 T.C. 1, 8 (2004). However, at no time has
petitioner raised a viable challenge to the amounts assessed
against him. His arguments boil down to a claim that the
Internal Revenue Service (IRS) is precluded from collecting
interest and penalties because of procedural errors. Although he
broadly alleges issues as to the amounts of tax, he has not
identified or proven any errors as to the assessed amounts.
Petitioner’s primary contention, which permeates several
different claims of violation of “due process”, is that the IRS
erroneously granted section 6015(f) relief to his former spouse.
Petitioner claims that he is entitled to raise this issue under
section 6330(c)(2)(A)(i). He argues that his wife and her
demands during divorce proceedings caused the unpaid liabilities
and that he did not receive adequate notice before she was
granted relief. He did not, however, present any persuasive or
admissible evidence in support of those claims.
In the petition in this case, in numerous meritless motions,
and in his posttrial briefs, petitioner has merely repeated his
broad unsupported assertions that he has been denied due process
of law and that the IRS has not proceeded properly. Despite the
opportunity to testify at trial, petitioner declined to do so,
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