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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 (e.g., an
offer in compromise) 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
for an abuse of discretion under section 6330(d)(1), generally we
consider only arguments, issues, and other matters that were
raised at the section 6330 hearing or otherwise brought to the
attention of Appeals. Magana v. Commissioner, 118 T.C. 488, 493
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