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amount of the unpaid tax and of the taxpayer’s right to a section
6330 hearing at least 30 days before the levy is begun.
If a section 6330 hearing is requested, the hearing is to be
conducted by the Office of Appeals, and, at the hearing, the
Appeals officer conducting it must verify that the requirements
of any applicable law or administrative procedure have been met.
Sec. 6330(b)(1), (c)(2). 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 also raise
challenges to the existence or amount of the underlying tax
liability at a 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); see Montgomery v.
Commissioner, 122 T.C. 1 (2004).
This Court has jurisdiction under section 6330 to review the
Commissioner’s administrative determinations. Sec. 6330(d); see
Iannone v. Commissioner, 122 T.C. 287, 290 (2004). Where, as
here, the validity of the underlying tax liability is not at
issue, we review the determination for abuse of discretion. Sego
v. Commissioner, 114 T.C. 604, 610 (2000); Goza v. Commissioner,
114 T.C. 176, 183 (2000). Whether an abuse of discretion has
occurred depends upon whether the exercise of discretion is
without sound basis in fact or law. See Freije v. Commissioner,
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