Merry J. Chandler - Page 6

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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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