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decide whether respondent abused his discretion in filing the
lien. That question depends on whether respondent’s failure to
accept petitioner’s offers was an abuse of discretion. Nearly 4
years separated the first and second offer, and the second offer
was substantially less than the first. Because the making of the
second offer was so long after the first and the second offer
preceded the filing of the lien, we need to consider only whether
respondent abused his discretion in rejecting the second offer.7
Section 6320 provides that a taxpayer shall be notified in
writing by the Secretary of the filing of a Federal tax lien and
provided with an opportunity for an administrative hearing. Sec.
6320(b). Hearings under section 6320 are conducted in accordance
with the procedural requirements set forth in section 6330. Sec.
6320(c).
When an Appeals officer issues a determination regarding a
disputed collection action, a taxpayer may seek judicial review
with the Tax Court or a District Court, as appropriate. Sec.
6330(d); see Davis v. Commissioner, 115 T.C. 35, 37 (2000); Goza
v. Commissioner, 114 T.C. 176, 179 (2000). Where the validity of
the underlying tax liability is properly at issue, the Court will
review the matter de novo. Sego v. Commissioner, 114 T.C. 604,
610 (2000). However, when the validity of the underlying tax is
7 We consider the first offer only to the extent helpful to
determine whether respondent abused his discretion in rejecting
the second offer.
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