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deficiency or did not otherwise have an opportunity to dispute
the tax liability. Sec. 6330(c)(2)(B).
Pursuant to section 6330(d)(1), within 30 days of the
issuance of a notice of determination, the taxpayer may appeal
the determination to this Court if we have jurisdiction over the
underlying tax liability. Where the validity of the underlying
tax liability is properly at issue, the Court will review the
matter de novo. Sego v. Commissioner, 114 T.C. 604, 610 (2000);
Goza v. Commissioner, 114 T.C. 176, 181 (2000). Where the
validity of the underlying tax liability is not properly at
issue, the Court will review the Commissioner’s determination for
an abuse of discretion. Sego v. Commissioner, supra at 610; Goza
v. Commissioner, supra at 181.
Petitioner received a statutory notice of deficiency for the
years in issue, and thus his underlying tax liability is not
properly at issue. Accordingly, we review respondent’s
determination for an abuse of discretion. See Sego v.
Commissioner, supra at 610; Goza v. Commissioner, supra at 181.
Petitioner argues that the settlement officer abused his
discretion by terminating the telephone conference of December
14, 2004. The termination of the telephone call effectively
negated the hearing, according to petitioner, so that he did not
receive the hearing required by section 6330. We disagree.
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