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hearing, but only 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).
At the conclusion of the hearing, the Appeals officer must
determine whether and how to proceed with collection and shall
take into account (i) the verification that the requirements of
any applicable law or administrative procedure have been met,
(ii) the relevant issues raised by the taxpayer, (iii) challenges
to the underlying tax liability by the taxpayer, where permitted,
and (iv) whether any proposed collection action balances the need
for the efficient collection of taxes with the legitimate concern
of the taxpayer that the collection action be no more intrusive
than necessary. Sec. 6330(c)(3).
We have jurisdiction to review the Appeals officer's
determination 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). Generally, we may
consider only those issues that the taxpayer raised during the
section 6330 hearing. See sec. 301.6330-1(f)(2), Q&A-F5, Proced.
& Admin. Regs.; see also Magana v. Commissioner, 118 T.C. 488,
493 (2002). Where the underlying tax liability is properly at
issue, we review the determination de novo. E.g., Goza v.
Commissioner, 114 T.C. 176, 181-182 (2000). Where the underlying
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