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Commissioner, 114 T.C. 604, 610 (2000); see also Barnes v.
Commissioner, T.C. Memo. 2006-150. We reject the determination
of Appeals only if the determination was arbitrary, capricious,
or without sound basis in fact or law. See Cox v. Commissioner,
126 T.C. 237, 255 (2006); Murphy v. Commissioner, 125 T.C. 301,
308, 320 (2005).
Where, as here, we decide the propriety of Appeals’s
rejection of an offer-in-compromise, we review the reasoning
underlying that rejection to decide whether the rejection was
arbitrary, capricious, or without sound basis in fact or law.
We do not substitute our judgment for that of Appeals, and we do
not decide independently the amount that we believe would be an
acceptable offer-in-compromise. See Murphy v. Commissioner,
supra at 320; see also Barnes v. Commissioner, supra; Fowler v.
Commissioner, T.C. Memo. 2004-163; Fargo v. Commissioner, T.C.
Memo. 2004-13, affd. 447 F.3d 706 (9th Cir. 2006). Nor do we
usually consider arguments, issues, or other matters raised for
the first time at trial, but we limit ourselves to matter brought
to the attention of Appeals. See Murphy v. Commissioner, supra
at 308; Magana v. Commissioner, 118 T.C. 488, 493 (2002).
“[E]vidence that * * * [a taxpayer] might have presented at the
section 6330 hearing (but chose not to) is not admissible in a
trial conducted pursuant to section 6330(d)(1) because it is not
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