Dina DeSalvo - Page 14

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          clearly unlawful, or without sound basis in fact or law.”  Ewing            
          v. Commissioner, 122 T.C. 32, 39 (2004); see also Woodral v.                
          Commissioner, 112 T.C. 19, 23 (1999).  Review for abuse of                  
          discretion includes “any relevant issue relating to the unpaid              
          tax or the proposed levy”, including “challenges to the                     
          appropriateness of collection actions” and “offers of collection            
          alternatives” such as offers in compromise.  Sec. 6330(c)(2)(A).            
          Questions about the appropriateness of the collection action                
          include whether it is proper for the Commissioner to proceed with           
          the collection action as determined in the notice of                        
          determination, and whether the type and/or method of collection             
          chosen by the Commissioner is appropriate.  See, e.g., Swanson v.           
          Commissioner, 121 T.C. 111, 119 (2003).                                     
               As previously noted, offers in compromise are a specifically           
          mentioned collection alternative, and they are therefore reviewed           
          under an abuse of discretion standard.  Sec. 6330(c)(2)(A)(iii).            
          Additionally, whether respondent may proceed with collection of             
          petitioner’s unpaid liabilities is a challenge to the                       
          appropriateness of collection.  See sec. 6330(c)(2)(A)(ii);                 
          Swanson v. Commissioner, supra.                                             
               Therefore, had petitioner raised the issue of the rejection            
          of her offer in compromise in her petition to this Court, we                
          would still hold summary judgment to be appropriate because there           








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