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HALPERN, J., concurring:
I. Introduction
I concur with the conclusion of the majority that respondent
may proceed with the collection action as determined in the
notice of determination with respect to each of petitioner’s
taxable years 1994, 1995, and 1998. I write separately princi-
pally to add some observations concerning what we have character-
ized as the “standard of review” (described infra) applicable to
our jurisdiction under section 6330(d)(1) to review a section
6330 determination.
II. Section 6330
Section 6330 entitles a taxpayer to notice and an opportu-
nity for a hearing before certain lien and levy actions are taken
by the Commissioner in furtherance of the collection from the
taxpayer of unpaid Federal taxes. At such required hearing (the
section 6330 hearing), the Appeals officer conducting the hearing
must verify that the requirements of any applicable law or
administrative procedure have been met. Sec. 6330(c)(1). The
taxpayer requesting the section 6330 hearing may raise “any
relevant issue relating to the unpaid tax or the proposed levy”.
Sec. 6330(c)(2)(A). The taxpayer may also raise challenges to
the existence or amount of the underlying tax liability “if the
person did not receive any statutory notice of deficiency for
such tax liability or did not otherwise have an opportunity to
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