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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
tax liability is not at issue, we review the determination for
abuse of discretion. Id. at 182. Whether an abuse of discretion
has occurred depends upon whether the exercise of discretion is
without sound basis in fact or law. See Ansley-Sheppard-Burgess
Co. v. Commissioner, 104 T.C. 367, 371 (1995).
Petitioner, proceeding pro se, seeks a refund of all income
taxes paid for taxable years 1995 through 2001. Our jurisdiction
in this case is confined, however, to a review of the Appeals
officer's determination approving a levy to collect unpaid tax
liabilities for 1997, 1998, and 1999. We shall treat petitioner
as contesting the Appeals officer's determination for all years,
and consider his arguments to the extent they have any bearing
thereon. In particular, we find that petitioner's communications
with the Appeals officer may be fairly construed as proposing a
collection alternative, and as raising the issue that payments he
made with respect to the years in issue were not properly
accounted for by respondent and that the tax reported as due on
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