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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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