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an issue as to the amount of a taxpayer’s tax liability. We need
not and do not address that issue.
None of the exceptions petitioner asks us to recognize are
valid. Under section 6330(c)(2)(B), petitioner is precluded from
challenging herein the amount of her 2002 Federal income tax
liability. Evidence relating to petitioner’s 2002 Federal income
tax liability is not relevant and will not be admitted.2
For the reasons stated, we shall deny petitioner’s motions
in limine, but we shall grant respondent’s motion in limine.
The issue as to petitioner’s claim for interest abatement
will be set for subsequent hearing.
An appropriate order will
be issued.
2 We note that in certain circumstances under sec. 6201(d)
respondent is required to seek reasonable verification of
taxpayer income reported by third parties on information returns
such as Forms 1099-B. For this verification requirement to be
triggered, however, a taxpayer must have cooperated with
respondent during respondent’s audit. Here, petitioner did not
participate in the audit, and sec. 6201(d) has no application.
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