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dispute such tax liability.” Sec. 6330(c)(2)(B); see also Urbano
v. Commissioner, 122 T.C. 384, 389-390 (2004); Montgomery v.
Commissioner, 122 T.C. 1, 9-10 (2004).
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 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).
Section 6330(d) provides for judicial review of the
administrative determination in the Tax Court or a Federal
District Court, as may be appropriate. Where the validity of the
underlying tax liability is properly at issue, the Court will
review the matter de novo. However, where the validity of the
underlying tax liability is not properly at issue, the Court will
review the Commissioner’s administrative determination for abuse
of discretion. Goza v. Commissioner, 114 T.C. 176, 181-182
(2000).
Petitioner does not seek to challenge his underlying tax
liabilities. We therefore review respondent’s determination for
abuse of discretion. See Lunsford v. Commissioner, 117 T.C. 183,
185 (2001); Goza v. Commissioner, supra. We generally consider
only arguments, issues, and other matters that were raised at the
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