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[the levy notice] relates." Sec. 6330(b)(2). The taxpayer may
raise at the hearing "any relevant issue relating to the unpaid
tax or the proposed levy". Sec. 6330(c)(2)(A). The taxpayer may
also raise challenges to the existence or amount of the
underlying tax liability at a 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). The underlying
tax liability that may be challenged includes amounts reported as
due on a return. Montgomery v. Commissioner, 122 T.C. 1 (2004).
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
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