Garnett E. Thorpe - Page 8

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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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