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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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