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substitution of other assets, an installment
agreement, or an offer-in-compromise.
(B) Underlying liability.–-The person may also
raise at the hearing challenges to the existence or
amount of the underlying tax liability for any tax
period if the person did not receive any statutory
notice of deficiency for such tax liability or did not
otherwise have an opportunity to dispute such tax
liability.
Pursuant to section 6330(d)(1), within 30 days of the
issuance of the notice of determination, the taxpayer may appeal
that determination to this Court if we would normally have
jurisdiction over the underlying tax liability. Moore v.
Commissioner, 114 T.C. 171, 175 (2000).
II. Standard of Review
A central question in the present case is the standard of
review to be applied. Although section 6330 does not prescribe
the standard of review that the Court is to apply in reviewing
the Commissioner’s administrative determinations, we have stated
that where the validity of the underlying tax liability is
properly at issue, the Court will review the matter de novo.
Where the validity of the underlying tax liability is not
properly at issue, however, the Court will review the
Commissioner’s administrative determination for abuse of
discretion. Sego v. Commissioner, 114 T.C. 604, 610 (2000); Goza
v. Commissioner, supra at 181-182.
Generally, under section 6330(c)(2)(B), issues that are
reviewed de novo include those such as a redetermination of the
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