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action. In the determination, the hearing officer must confirm
that he or she took into consideration the verification presented
under section 6330(c)(1). Sec. 6330(c)(3)(A); sec. 301.6320-
1(e), Proced. & Admin. Regs. In addition, the determination must
take into consideration any issues appropriately raised by the
taxpayer, offers by the taxpayer for collection alternatives, and
whether the disputed collection action represents a balance
between the Government’s need for efficient collection of taxes
and the taxpayer’s concerns regarding the intrusiveness of the
proposed collection action. Sec. 6330(c). If the taxpayer
disagrees with the hearing officer’s determination, the taxpayer
has the right to seek judicial review of the determination by
appealing to this Court or, if this Court lacks jurisdiction over
the underlying tax liability, to a Federal District Court. Sec.
6330(d).
If the taxpayer files a timely petition for judicial review,
the applicable standard of review depends upon whether the
underlying tax liability is at issue. Where the underlying tax
liability is not at issue, the Court will review the Appeals
officer’s determination for abuse of discretion. Sego v.
Commissioner, supra at 610.
In his amended petition, petitioner enumerates a plethora of
“errors” allegedly committed by the Appeals Office in making its
determination upholding the nominee lien filed against the
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