- 4 - v. Commissioner, 114 T.C. 604, 610 (2000); Goza v. Commissioner, 114 T.C. 176, 183 (2000); Wooten v. Commissioner, T.C. Memo. 2003-113. In so doing, we do not conduct an independent review of what would be an appropriate collection alternative. Van Vlaenderen v. Commissioner, T.C. Memo. 2003-346. We review only whether the Appeals officer’s determination was arbitrary, capricious, or without sound basis in fact or law. See Woodral v. Commissioner, 112 T.C. 19, 23 (1999). Under section 6330, a taxpayer is entitled to a hearing in which he or she may raise any relevant issue relating to the unpaid tax or the proposed levy, including offers of collection alternatives such as an offer in compromise. Sec. 6330(b) and (c)(2). In the present case, petitioner appears to contend that respondent should not proceed with collection because of abuses she and her family have suffered by various Government agencies. Petitioner does not otherwise present any argument that the Appeals officer’s actions were an abuse of discretion. On the basis of the information considered by the Appeals officer, we cannot conclude that the Appeals officer’s determination to proceed with collection action was an abuse of discretion. See Van Vlaenderen v. Commissioner, supra; Crisan v. Commissioner, T.C. Memo. 2003-318; Willis v. Commissioner, T.C. Memo. 2003-302; O’Brien v. Commissioner, T.C. Memo. 2003-290; Schulman v. Commissioner, T.C. Memo. 2002-129. Indeed, when thePage: Previous 1 2 3 4 5 6 Next
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