Johnny and M. Suzan Black - Page 6

               believed they could obtain a “better deal” in Tax Court                
               and wanted to leave it up to them for a final                          
               determination.  You have not shown you are entitled to                 
               any reduction on your tax liabilities via the Offer in                 
               Petitioners do not dispute that their net equity in                    
          available assets exceeded the amount offered in compromise, and             
          in fact exceeded the total tax liability in issue.                          
               Section 6320 provides that a taxpayer shall be notified in             
          writing by the Secretary of the filing of a Federal tax lien and            
          provided with an opportunity for an administrative hearing.  Sec.           
          6320(b).  A hearing under section 6320 is conducted in accordance           
          with the procedural requirements set forth in section 6330.  Sec.           
          6320(c).  At the administrative hearing, a taxpayer is entitled             
          to raise any relevant issue relating to the unpaid tax, including           
          collection alternatives such as an offer in compromise or an                
          installment agreement.3  Sec. 6330(b) and (c)(2); sec. 301.6320-            
          1(e)(1), Proced. & Admin. Regs.                                             
               This Court has jurisdiction under section 6330 to review the           
          Commissioner’s administrative determinations.  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           

               3  Sec. 7122(d)(2) allows a taxpayer to appeal any rejection           
          of an offer or agreement to the IRS Office of Appeals.                      

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