Theodore Skeriotis - Page 6

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          see Sego v. Commissioner, 114 T.C. 604, 609 (2000); Goza v.                 
          Commissioner, 114 T.C. 176, 180 (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.                                                         
               Because petitioner received notices of deficiency but failed           
          to petition this Court to redetermine the deficiencies,                     
          petitioner is not entitled in this collection proceeding to                 
          challenge his underlying liabilities for 2000 and 2001.  See sec.           
          6330(c)(2)(B); Sego v. Commissioner, supra at 610; Goza v.                  
          Commissioner, supra at 182-183.  Accordingly, we review                     
          respondent’s determination for an abuse of discretion.  See Sego            
          v. Commissioner, supra at 610.                                              
               In his response to respondent’s motion for summary judgment,           
          petitioner’s primary argument appears to be that the notices of             
          deficiency, as well as numerous other documents, including                  
          respondent’s pleadings in this case, respondent’s tax return                
          forms, and correspondence that respondent sent to him, are                  
          invalid because they lack valid Office of Management and Budget             
          numbers.3  Petitioner’s argument is without merit.  See, e.g.,              
          United States v. Dawes, 951 F.2d 1189, 1191 (10th Cir. 1991);               

               3 In making this argument, petitioner appears to rely on               
          provisions of the Paperwork Reduction Act of 1980, 44 U.S.C.                
          secs. 3501-3520 (2000).                                                     





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