Julian Quinton Johnson - Page 16

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             review is not limited to the administrative record.”  See                
             also Ewing v. Commissioner, 122 T.C. 32 (2004).                          
             Respondent’s motion for summary judgment in this case does               
             not cite Robinette and, thus, it gives us no reason to                   
             distinguish that case or to conclude that its holding does               
             not govern our opinion here.                                             
                  Absent special circumstances, in an appeal of a levy                
             determination we will consider only arguments, issues,                   
             and other matters that were raised at the section 6330(b)                
             hearing or otherwise brought to the attention of the                     
             Appeals Office.  See Robinette v. Commissioner, supra                    
             at 101-103; Ewing v. Commissioner, supra at 41; Magana v.                
             Commissioner, 118 T.C. 488, 493-494 (2002).  Thus, while                 
             the taxpayer may not be limited to the evidence contained                
             in the administrative record of the levy determination,                  
             it must appear that the matters raised before this Court                 
             were also raised before the Appeals Office.  See Robinette               
             v. Commissioner, supra at 101-103.                                       
                  In this case, the grounds for relief stated in                      
             petitioner’s petition, as quoted above, are terse but                    
             can be read as raising an issue about the appropriateness                
             of collection actions (i.e., the statement in the petition               
             that petitioner is “homeless, not working and in recoverey               






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