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Davis v. Commissioner, 115 T.C. 35, 37 (2000); Goza v.
Commissioner, 114 T.C. 176, 179-180 (2000). Section 6330(c)(2)
specifies issues that the taxpayer may raise at the hearing. The
taxpayer may raise "any relevant issue relating to the unpaid tax
or the proposed levy" including spousal defenses, challenges to
the appropriateness of collection actions, and alternatives to
collection. Sec. 6330(c)(2)(A). The taxpayer also may challenge
the underlying tax liability if the taxpayer did not receive a
statutory notice of deficiency or did not otherwise have an
opportunity to dispute the tax liability. Sec. 6330(c)(2)(B).
Section 6330(c)(3) provides that the determination of the Appeals
officer shall take into consideration, inter alia, the issues
raised by the taxpayer. We review the determination de novo when
the underlying tax liability is in dispute, Goza v. Commissioner,
supra at 181-182, and under an abuse of discretion standard when
it is not, Sego v. Commissioner, 114 T.C. 604, 610 (2000); Goza
v. Commissioner, supra at 182.
Two of the principal arguments petitioner raises are that he
did not receive the hearing to which he was entitled under
section 6330 because he was not permitted to record the hearing
and that the Appeals officer refused to consider arguments
pertaining to the underlying tax liabilities (because petitioner
reported those liabilities as due on his returns). The hearing
in this case was conducted, and the determination issued, before
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