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    The Commissioner moved for summary judgment, and the motion was argued during a trial session in Las Vegas.5 Discussion Summary judgment is appropriate where it is shown that "there is no genuine issue as to any material fact and that a decision may be rendered as a matter of law." Rule 121(b); Fla. We find no authority elsewhere in the Code to read that section's command that the IRS allow challenges to liability in some situations to mean that the IRS must allow challenges to liability in all situations. They claim that making an OIC-DATL is not a challenge to their underlying liability. Since petitioner is precluded from questioning the underlying liabilities, his offer would not provide him any relief...." But the Baltics are right in noting that Hajiyani --in the text --held that the Commissioner was justified in not considering an OIC-DATL because the taxpayers hadn't even submitted one before the notice of determination came out.