Christopher Iames v. Commissioner of I.R.S.

WILKINSON, Circuit Judge:

This tax administration case presents the question of whether the appellant, Christopher lames, may contest his tax liability in a collection due process (CDP) hearing under Section 6330 of the Internal Revenue Code. lames unsuccessfully challenged his liability in a preassessment hearing before the Office of Appeals of the Internal Revenue Service (IRS). He later sought to raise the same issue before the same administrative unit in his CDP hearing. The Office of Appeals concluded that Section 6330 prohibited him from disputing his liability a second time, and the Tax…