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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) (challenge to
appropriateness of collection reviewed for abuse of discretion).
Abuse of discretion is the proper standard of review in this
case. The introductory language of section 6330(c)(2)(A)
encompasses the situation at bar. Mr. Talbott’s conclusion that
respondent had acted properly in declaring petitioner’s offer-in-
compromise in default and that issuing a notice of determination
was proper is a “relevant issue relating to the unpaid tax or the
proposed levy”. Further, offers in compromise are a specifically
mentioned collection alternative. Sec. 6330(c)(2)(A)(iii).
Additionally, whether respondent may proceed with collection of
petitioner’s unpaid liability is a challenge to the
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