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(and cases cited therein), affd. 64 Fed. Appx. 492 (6th Cir.
2003). In the present case, respondent satisfied the
verification requirement when petitioner was presented with
literal transcripts of his tax accounts for the years 1994
through 1998.
Besides satisfying the verification requirement, the
Commissioner also must take into consideration in his
determination any issues raised by the taxpayer under section
6330(c)(2) and whether any proposed collection action balances
the need for the efficient collection of taxes with the
legitimate concern of the taxpayer that any collection action be
no more intrusive than necessary. Sec. 6330(c)(3). Under
section 6330(c)(2), the taxpayer may raise any relevant issue
relating to the unpaid tax or the proposed levy, including but
not limited to challenges to the appropriateness of the
collection actions and offers of collection alternatives.
2. Standard of Review
This Court has jurisdiction to review the Commissioner’s
administrative determination under section 6330. Sec. 6330(d).
Where, as here, the validity of the underlying tax liability is
not at issue, we review the determination for abuse of
discretion. Sego v. Commissioner, 114 T.C. 604, 610 (2000); Goza
v. Commissioner, 114 T.C. 176, 183 (2000).
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