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Commissioner, 114 T.C. 604, 609 (2000); Goza v. Commissioner, 114
T.C. 176, 180 (2000). If a taxpayer received a statutory notice
of deficiency for the years in issue or otherwise had the
opportunity to dispute the underlying tax liability, the taxpayer
is precluded from challenging the existence or amount of the
underlying tax liability. Sec. 6330(c)(2)(B); Sego v.
Commissioner, supra at 610-611; Goza v. Commissioner, supra at
182-183.
Petitioner received notices of deficiency for 1997, 1999,
2000, and 2001. Accordingly, he cannot challenge his underlying
liabilities for those years. See sec. 6330(c)(2)(B); Sego v.
Commissioner, supra at 610-611; Goza v. Commissioner, supra at
182-183.
At trial, the Court gave petitioner several opportunities to
present evidence regarding his underlying liabilities for 1998
and 2002. The Court asked petitioner several times whether he
wanted to address his deficiencies or underlying liabilities.
When asked by the Court whether he had anything to say about his
deficiencies or underlying liabilities, petitioner answered “No.”
Accordingly, we review respondent’s determination for 1997, 1998,
1999, 2000, 2001, and 2002 for an abuse of discretion. See Sego
v. Commissioner, supra at 610.
Settlement Officer Feist conducted a thorough review of the
financial information that petitioner provided to him. Upon the
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