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not receive a notice of deficiency or did not otherwise have an
opportunity to dispute that tax liability. Sec. 6330(c)(2)(B);
see Sego v. Commissioner, 114 T.C. 604, 609 (2000); Goza v.
Commissioner, 114 T.C. 176, 180-181 (2000).
If the validity of the underlying tax liability is properly
at issue, we review that issue de novo. See Sego v.
Commissioner, supra at 609-610. Other issues we review for abuse
of discretion. Id.
1. Underlying Tax Liability
Petitioner challenges his underlying liabilities for 1987,
1990, and 1991 on the ground that alleged net operating loss
carrybacks and carryforwards from 1988 and 1989 should eliminate
any liabilities for these years. Because petitioner received a
notice of deficiency for his tax years 1987 through 1991, he is
not entitled to challenge the existence or amount of his tax
liabilities for these years in this collection proceeding. See
secs. 6320(c), 6330(c)(2)(B); Sego v. Commissioner, supra at 609;
Goza v. Commissioner, supra at 180-181. Moreover, because this
Court adjudicated petitioner’s liabilities for these years
pursuant to a stipulated decision in the prior deficiency
proceeding, the doctrine of res judicata prevents petitioner from
relitigating in this proceeding his liabilities for 1987, 1990,
and 1991. See Newstat v. Commissioner, T.C. Memo. 2004-208.
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