- 7 - liability. Sec. 6330(c)(2)(B); Sego v. Commissioner, 114 T.C. 604, 609 (2000); Goza v. Commissioner, 114 T.C. 176, 180-181 (2000). A prior opportunity to dispute the underlying tax liability includes a prior hearing pursuant to section 6330 concerning the liability where the taxpayer fails to seek judicial review of the Appeals Office's determination arising from that hearing. Bell v. Commissioner, 126 T.C. 356 (2006). The sole material3 issue raised by petitioner at his hearing and at trial with respect to the unpaid 1997 tax and the lien is his claim that he did not receive the income that gave rise to the unpaid liability. Respondent argues that petitioner's contention constitutes a challenge to the underlying tax liability for 1997 that is precluded under section 6330(c)(2)(B) because petitioner had a previous opportunity to dispute the liability. We agree. 3 Two other immaterial issues were raised by petitioner. First, petitioner complains of respondent's failure to provide him with a copy of his 1997 return. The Appeals officer, however, was not required to furnish documentation or information to petitioner beyond proof of the assessment. See, e.g., Nestor v. Commissioner, 118 T.C. 162, 166-167 (2002); Scott v. Commissioner, T.C. Memo. 2007-91. Second, petitioner complains that respondent has sent information regarding petitioner's tax liabilities to an unauthorized third party. Our jurisdiction in this case is limited to the issue of whether respondent may proceed with the proposed collection action. Petitioner's remedy for any unauthorized disclosure of his personal tax information lies in the U.S. District Court. See sec. 7431.Page: Previous 1 2 3 4 5 6 7 8 9 10 NextLast modified: November 10, 2007