Arthur A. Lemann III and Roberta A. Lemann - Page 13

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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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