Clarification of Tax Court jurisdiction to determine tax liability in collection due process appeals

(a) In general Section 6330(c)(2)(B) is amended by inserting in the Tax Court or any other Federal court (other than through a suit for a refund under section 7442 or under section 1346(a)(1) of title 28, United States Code) after otherwise have an opportunity to dispute such tax liability. (b) Underlying tax liability Section 6330(c)(4) is amended by striking An issue may not be raised and inserting An issue which is not related to the amount or existence of the underlying tax liability may not be raised.