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We approach the dispute in this case in the context of
review of a hearing conducted under section 6330. Under section
6330, a taxpayer is entitled to one hearing in which he may
propose alternatives to collection, such as the levy action
proposed by respondent on March 15, 2001. See sec. 6330(b), (c),
and (d). Where, as here, liability is not an issue, the Appeals
officer’s determination is reviewed for abuse of discretion.
Goza v. Commissioner, 114 T.C. 176, 181-182 (2000). Generally,
we consider only issues raised at the hearing before the Appeals
Office. Magana v. Commissioner, 118 T.C. 488, 493 (2002). Thus,
we do not conduct an independent review of what would be an
acceptable offer in compromise. We review only whether the
Appeals officer’s refusal to accept the offer in compromise made
by petitioner was arbitrary, capricious, or without sound basis
in fact or law. See Woodral v. Commissioner, 112 T.C. 19, 23
(1999).
It is possible, as petitioner contends, that the revenue
officer’s financial analysis, based on the information that
petitioner had provided, was flawed. We cannot, however,
conclude that the information that petitioner provided was
reliable or that consideration of his amended offer in compromise
of $9,756 would have changed the determination. The Appeals
officer’s determination was based on analysis of the information
that petitioner submitted. The Appeals officer adopted the
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