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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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