Deirdre G. McNamara - Page 5

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          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 the           






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