Francis A. Morlino - Page 6

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          officer) conducting it must verify that the requirements of any             
          applicable law or administrative procedure have been met.  Sec.             
          6330(b)(1), (c)(1).  The taxpayer may raise at the hearing any              
          relevant issue relating to the unpaid tax or the proposed levy.             
          Sec. 6330(c)(2)(A).  The taxpayer may contest the existence or              
          amount of the underlying tax liability at the hearing if the                
          taxpayer did not receive a statutory notice of deficiency with              
          respect to the underlying tax liability or did not otherwise have           
          an opportunity to dispute that liability.  Sec. 6330(c)(2)(B).              
               At the conclusion of the hearing, the Appeals officer must             
          determine whether and how to proceed with collection, taking into           
          account, among other things, collection alternatives proposed by            
          the taxpayer and whether any proposed collection action balances            
          the need for the efficient collection of taxes with the                     
          legitimate concern of the taxpayer that the collection action be            
          no more intrusive than necessary.  See sec. 6330(c)(3).                     
               We have jurisdiction to review the Appeals officer’s                   
          determination 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, we review the determination de              
          novo.  E.g., Goza v. Commissioner, 114 T.C. 176, 181-182 (2000).            
          Where the underlying tax liability is not at issue, we review the           
          determination for abuse of discretion.  Id. at 182.  In reviewing           

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