- 3 - 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.Page: Previous 1 2 3 4 5 6 NextLast modified: March 27, 2008