Talaske v. Comr., T.C. Sum. Op. 2011-33

(taxpayer received Form 1099-C showing cancellation of credit card debt of $20,291.22, but filed return without reporting such amount as income; IRS issued deficiency notice and taxpayer did not file petition for redetermination and IRS assessed deficiency along with interest; taxpayer did not pay outstanding liability and IRS sent taxpayer "Final Notice of Intent to Levy and Notice of Your Right To A Hearing"; taxpayer filed request for "Collection Due Process or Equivalent Hearing" which was rejected; taxpayer then petitioned Tax Court, but Tax Court noted that, by statute, Court cannot review matter because taxpayer had prior opportunity to dispute underlying liability and failed to do so).