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collection alternatives; 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). A hearing may be conducted face to face, by telephone,
or through written correspondence. Sec. 301.6330-1(d)(2), Q&A-
D7, Proced. & Admin. Regs.
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). An abuse of discretion occurs when
an Appeals officer takes action that is arbitrary, capricious, or
without sound basis in fact or law. See Woodral v. Commissioner,
112 T.C. 19, 23 (1999).
B. Separation of Joint and Several Liability
In general, spouses are jointly and severally liable for any
tax liability arising from a joint return. Sec. 6013(d)(3). At
a collection due process hearing, a taxpayer is entitled to raise
relevant spousal defenses, including a request for relief
from joint and several liability on a joint return under section
6015. Sec. 6330(c)(2)(A)(i). When a section 6015 claim is
raised at a CDP hearing, the claim is governed in all respects by
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