- 11 - related litigation in this Court, challenge the underlying tax liability. Secs. 6320(c), 6330(c)(2)(B); Lewis v. Commissioner, 128 T.C. __, __ (2007) (slip op. at 24); Sego v. Commissioner, 114 T.C. 604, 610-611 (2000); Goza v. Commissioner, 114 T.C. 176, 182-183 (2000); sec. 301.6320-1(e)(1), Proced. & Admin. Regs. Thus, where a taxpayer has received a prior lien or levy notice under section 6320 or section 6330 which could have been appealed to respondent’s Appeals Office, relating to the same year and the same underlying tax liability as is involved in a subsequent lien or levy notice, the taxpayer is treated with regard to the subsequent lien or levy notice as already having had a prior opportunity to dispute the underlying tax liability. Sec. 301.6320-1(e)(3), Q&A-E2, Q&A-E7, Proced. & Admin. Regs. Section 301.6320-1(e)(3), Q&A-E2, Proced. & Admin. Regs., explains as follows: An opportunity to dispute a liability includes a prior opportunity for a conference with Appeals that was offered either before or after the assessment of the liability. After requesting and receiving a copy of respondent’s notice of deficiency, at petitioner’s equivalent hearing with respondent’s Appeals Office relating to respondent’s June 17, 2002, second levy notice, petitioner discussed and disputed with respondent’s Appeals Office her alleged discharge of indebtednessPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 NextLast modified: November 10, 2007