Linda L. Pool - Page 8

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               Pursuant to section 6330(c)(2)(A), a taxpayer may raise at             
          the section 6330 hearing any relevant issue with regard to the              
          Commissioner’s collection activities, including spousal defenses,           
          challenges to the appropriateness of the Commissioner’s intended            
          collection action, and alternative means of collection.  Sego v.            
          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 1999, 2000,              
          and 2003.  Accordingly, she cannot challenge her underlying                 
          liabilities.  See sec. 6330(c)(2)(B); Sego v. Commissioner, supra           
          at 610-611; Goza v. Commissioner, supra at 182-183.  Therefore,             
          we review respondent’s determination for an abuse of discretion.            
          See Sego v. Commissioner, supra at 610.                                     
               Petitioner has failed to raise a spousal defense, make a               
          valid challenge to the appropriateness of respondent’s intended             
          collection action, or offer alternative means of collection.                
          These issues are now deemed conceded.  See Rule 331(b)(4).                  







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