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Appeals officer engaged in a discussion wherein petitioner sought
to contest the underlying tax liability. The Appeals officer
advised petitioner that she was not entitled to contest the
underlying tax liability because she had received a notice of
deficiency for 2002.
Subsequently, petitioner was provided with a letter
explaining her collection alternatives, and she thereafter
submitted an offer-in-compromise raising doubt as to the
underlying tax liability. Respondent mailed petitioner a Notice
of Determination Concerning Collection Action Under Section
6330, dated July 12, 2006, advising that he intended to proceed
with collection because petitioner was not entitled to contest
the underlying tax liability in the context of a collection due
process proceeding under section 6320 or 6330.2
Discussion
The only question we consider, in the context of this
collection case, is whether petitioner is entitled to challenge
the underlying tax liability. Respondent moved for summary
judgment, contending that as a matter of law petitioner is not
entitled to challenge the underlying 2002 tax liability.
Petitioner has challenged only the merits of the underlying tax
2 We note that respondent used the address shown on
petitioner’s 2002 return on all correspondence and notices sent
to petitioner.
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Last modified: March 27, 2008