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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).
We have jurisdiction to review the Appeals officer's
determination where 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). Generally, in reviewing
the Appeals officer's determination for abuse of discretion we
may consider only those issues that the taxpayer raised during
the section 6330 hearing. See sec. 301.6330-1(f)(2), Q&A-F5,
Proced. & Admin. Regs.; see also Magana v. Commissioner, 118 T.C.
488, 493 (2002). Where the underlying tax liability is properly
at issue, we review the determination de novo. E.g., Goza v.
Commissioner, 114 T.C. 176, 181-182 (2000). Where the underlying
tax liability is not at issue, we review the determination for
abuse of discretion. Id. 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,
125 T.C. 14, 23 (2005); Ansley-Sheppard-Burgess Co. v.
Commissioner, 104 T.C. 367, 371 (1995).
The issues raised by petitioners with the Appeals officer
and herein concern only collection alternatives. Petitioners
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