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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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