Daniel J. Ford - Page 4

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          6320 and/or 6330, sustaining the proposed levy.  Petitioner                 
          timely petitioned the Court.                                                
               Section 6330 provides that no levy may be made on any                  
          property or right to property of a person unless the Secretary              
          first notifies the person in writing of the right to a hearing              
          before respondent’s Appeals Office.  Section 6330(c)(1) provides            
          that the Appeals officer must verify at the hearing that                    
          applicable laws and administrative procedures have been followed.           
          The Appeals officer may rely on a Form 4340 for purposes of                 
          complying with section 6330(c)(1).  Nestor v. Commissioner, 118             
          T.C. 162, 166 (2002).  At the hearing, the person may raise any             
          relevant issue relating to the unpaid tax or the proposed levy,             
          including appropriate spousal defenses, challenges to the                   
          appropriateness of collection actions, and collection                       
          alternatives.  Sec. 6330(c)(2)(A).  The person may challenge the            
          existence or amount of the underlying tax liability, however,               
          only 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.  Sec. 6330(c)(2)(B).             
               In the instant case, petitioner does not challenge the                 
          underlying liabilities.  Consequently, we review respondent’s               
          determination for abuse of discretion.  See Goza v. Commissioner,           
          114 T.C. 176, 181-182 (2000); Sego v. Commissioner 114 T.C. 604,            

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