Carolyn D. Ramirez - Page 8

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          Federal taxes.  Upon request, a taxpayer is entitled to a “fair             
          hearing” conducted by an impartial officer from the Office of               
          Appeals.  Sec. 6330(b)(1), (3).  Such a hearing need not be                 
          conducted face-to-face; a taxpayer may receive a fair hearing by            
          telephone or through written correspondence.  Sec. 301.6330-                
          1(d)(2) Q&A-D7, Proced. & Admin. Regs.  At the hearing, the                 
          Appeals officer is required to:  (1)  Obtain verification from              
          the Secretary that the requirements of applicable law and                   
          administrative procedure have been met, (2) consider certain                
          issues raised by the taxpayer such as collection alternatives               
          including an installment agreement or an offer in compromise, and           
          (3) consider 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).                                    
               This Court has jurisdiction to review the Commissioner’s               
          administrative determination under section 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, 181-182 (2000).  In doing so, under the                       
          circumstances of this case, we do not conduct an independent                
          review of what would be an acceptable offer in compromise.                  
          Rather, we review only whether the Appeals officer’s decision to            






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