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thereof.” Id., Q&A-D6, Proced. & Admin. Regs. The Appeals
officer conducting the collection due process hearing must verify
that the requirements of any applicable law or administrative
procedure have been met. Sec. 6330(c)(1). Section 6330(c)
prescribes the relevant matters that a person may raise at the
collection due process hearing, including spousal defenses, the
appropriateness of respondent’s proposed collection action, and
possible alternative means of collection. A taxpayer may contest
the existence or amount of the underlying tax liability at a
collection due process hearing if the taxpayer did not receive a
statutory notice of deficiency with respect to the underlying tax
liability or did not otherwise have an opportunity to dispute
that liability. Sec. 6330(c)(2)(B).
Following the collection due process hearing, the Appeals
officer must determine whether the collection action is to
proceed, taking into account the verification the Appeals officer
has made, the issues raised by the taxpayer at the hearing, and
whether the 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)(3). We have jurisdiction to
review such determinations where we have jurisdiction over the
type of tax involved in the case. Sec. 6330(d)(1)(A); see
Iannone v. Commissioner, 122 T.C. 287, 290 (2004). Where the
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