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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). Generally, we
may consider only those issues that the taxpayer raised
during the section 6330 hearing. See sec. 301.6330-1(f)(2),
Q&A-F5, Proced. & Admin. Regs.; see also Magana v.
Commissioner, 118 T.C. 488, 493. 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. Whether an abuse of discretion has occurred depends
upon whether the exercise of discretion is without sound
basis in fact or law. See Ansley-Sheppard-Burgess Co. v.
Commissioner, 104 T.C. 367, 371 (1995).
II. Arguments of the Parties
Petitioners dispute the adjustments on the Form 4549-CG
(the adjustments). They also argue that none of their 1995
income tax liability remains unpaid. Respondent argues that
petitioners failed to raise the adjustments during the
section 6330 hearing and that they did not either during
that hearing or at trial provide any evidence showing
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