John R. Forrest - Page 6

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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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