- 15 - 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 recovereyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011