William J. McCorkle - Page 11

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          statutory notice of deficiency for, or did not otherwise have an            
          opportunity to dispute, such tax liability.  Sec. 6330(c)(2)(B).            
               Following the hearing, the Appeals officer must determine              
          whether the collection action is to proceed, taking into account            
          the verification the Appeals officer has made, the issues raised            
          by the taxpayer at the hearing, and whether the collection action           
          “balances the need for the efficient collection of taxes with the           
          legitimate concern of the * * * [taxpayer] that any collection              
          action be no more intrusive than necessary.”  Sec. 6330(c)(3)(C).           
          We have jurisdiction to review such determinations where we have            
          jurisdiction over the type of tax involved in the case.  Sec.               
          6330(d)(1)(A); see Iannone v. Commissioner, 122 T.C. 287, 290               
          (2004).  Where the underlying tax liability is properly at issue,           
          the taxpayer is entitled to a de novo hearing in this court.                
          E.g., Goza v. Commissioner, 114 T.C. 176, 181-182 (2000).  Where            
          the underlying tax liability is not properly at issue, we review            
          the determination for abuse of discretion.  Id. at 182.  When               
          faced with questions of law, as we are here (determining whether            
          petitioner may challenge the forfeiture order and whether                   
          respondent was obligated to defend against it), the standard of             
          review makes no difference.  Whether characterized as a review              
          for abuse of discretion or as a consideration "de novo" (of a               
          question of law), we must reject erroneous views of the law.  See           
          Cooter & Gell v. Hartmarx Corp., 496 U.S. 384 (1990); Abrams v.             






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