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We have jurisdiction to review the Appeals officer’s
determination if 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). If the underlying tax
liability is properly at issue, we review the determination de
novo. Goza v. Commissioner, supra at 181-182. If 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 the
Appeals officer. Magana v. Commissioner, 118 T.C. 488, 493
(2002); see also sec. 301.6330-1(f)(2), Q&A-F5, Proced. & Admin.
Regs. 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).
C. Standard of Review
Section 6330(c)(2)(B) provides that a person may challenge
“the existence or amount of the underlying tax liability for any
tax period if the person did not receive any statutory notice of
deficiency for such tax liability or did not otherwise have an
opportunity to dispute such tax liability.” We have held that
“it is reasonable to interpret the term ‘underlying tax
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