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had received a notice of deficiency for each of the years at
issue and that, consequently, petitioner could not challenge the
underlying tax liabilities. Sec. 6330(c)(2)(B); Goza v.
Commissioner, 114 T.C. 176, 183 (2000). The administrative
record also demonstrates that the presiding officer obtained the
required verification that applicable legal and administrative
procedures had been met and considered the issues raised by
petitioner during the hearing process, even though the arguments
were not relevant and were frivolous attempts to disrupt the
collection process.3 Finally, the Appeals officer conducted an
appropriate analysis as required by section 6330(c)(3)(C).
Petitioner did not show that there is a genuine issue as to
any of the material facts in this case, nor did petitioner raise
any issue of law that would preclude the entry of a summary
disposition under Rule 121. We shall grant respondent’s motion
for summary judgment.
To reflect the foregoing,
An appropriate order and
decision will be entered.
3Petitioner alleged that (1) the notices of deficiency were
void, (2) that there was a failure to generate an assessment
list, (3) that the Commissioner failed to certify and transmit an
assessment list, (4) that the Commissioner failed to record the
assessment, (5) that the Commissioner failed to provide record of
assessment at petitioner’s request, and (6) that the Commissioner
failed to send a notice of assessment.
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