OPINION
FOLEY, Judge:
The issue for decision is whether respondent abused his discretion when he precluded petitioner, at the 2005 hearing, from challenging petitioner's underlying tax liability and sustained the notice of Federal tax lien relating to petitioner's 1997 liability.
Background
Petitioner failed to file his 1997 Federal income tax return. By notice dated September 15, 2000, respondent determined a deficiency in...
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