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administrative determinations, we have stated that, where the
validity of the underlying tax liability is properly at issue,
the Court will review the matter de novo. Sego v. Commissioner,
114 T.C. 604, 610 (2000); Goza v. Commissioner, 114 T.C. 176, 181
(2000). Where the validity of the underlying tax liability is
not properly at issue, however, the Court will review the
Commissioner’s administrative determination for abuse of
discretion. Sego v. Commissioner, supra; Goza v. Commissioner,
supra. The term “underlying tax liability” in section 6330(d)(1)
includes any amounts allegedly owed by a taxpayer pursuant to the
tax laws. Katz v. Commissioner, 115 T.C. 329 (2000). This
includes the tax deficiency, additions to tax, and interest. Id.
As petitioner does not dispute the validity of the underlying tax
liability, we review respondent’s determination for an abuse of
discretion.
Petitioner’s claim regarding his inability to pay bears upon
issues such as collection alternatives or the appropriateness of
the collection action that the Court reviews for abuse of
discretion. An action constitutes abuse of discretion where it
is arbitrary, capricious, or without sound basis in fact or law.
Woodral v. Commissioner, 112 T.C. 19, 23 (1999).
The record reflects no abuse of discretion by respondent.
We have found that in the face of allegations of undue hardship,
a taxpayer must submit complete and current financial data to
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