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dispute such tax liability.” Sec. 6330(c)(2)(B). Following the
section 6330 hearing, the Appeals officer must determine whether
the collection action is to proceed, taking into account the
verification the Appeals officer has made, the issues raised by
the person requesting the hearing, and “whether any proposed
collection action balances the need for the efficient collection
of taxes with the legitimate concern of the person that any
collection action be no more intrusive than necessary.” Sec.
6330(c)(3). We have jurisdiction to review such determinations
where we have jurisdiction of the underlying tax liability. Sec.
6330(d)(1)(A).
III. The Nature of the Hearing Before Us
In Sego v. Commissioner, 114 T.C. 604, 610 (2000), we
discussed the standard of review that a court is to apply in
reviewing a section 6330 determination. After reviewing a
portion of the legislative history relevant to the enactment of
section 6330, we stated:
[W]here the validity of the underlying tax liability is
properly at issue, the Court will review the matter on
a de novo basis. However, where the validity of the
underlying tax liability is not properly at issue, the
Court will review the Commissioner’s administrative
determination for abuse of discretion.
See also Goza v. Commissioner, 114 T.C. 176, 181-183 (2000) (the
same). Perhaps a more instructive way to describe the process
involved when we review a section 6330 determination would be to
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