On September 2, 2021, the Tax Court issued a Memorandum Opinion in the case of Pazden v. Commissioner (T.C. Memo. 2021-108). The primary issues presented in Pazden were (1) whether Ms. Pazden is entitled to challenge her underlying tax liability for 2010, and (2) whether Appeals abused its discretion in sustaining the proposed levy in this case. Held: Nope and Nope. Background Ms. Pazden failed to timely file her 2010 Federal income tax return. The IRS thereafter sent Ms. Pazden a notice of deficiency dated June 3, 2013, based upon a substitute for return that the IRS had prepared under the authority conferred by IRC § 6020(b). The notice determined a deficiency of $449,934, as well as additions to tax under IRC § 6651(a)(1) for failure to file her tax return, IRC § 6651(a)(2) for failure to pay tax, and IRC § 6654 for failure to pay estimated tax, and…