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he or she may raise any relevant issue relating to the unpaid tax
or to the tax lien, including challenges to the appropriateness
of the collection action and “offers of collection alternatives,
which may include the posting of a bond, the substitution of
other assets, an installment agreement, or an offer-in-
compromise.” Sec. 6330(c)(2)(A); see also sec. 6320(c). A
determination takes into account consideration of the
verification that the requirements of the applicable law and
administrative procedures have been met and “whether any proposed
collection action balances the need for the efficient collection
of taxes with the legitimate concern of the person that any
collection action be no more intrusive than necessary.” Sec.
6330(c)(3)(C).
There is no issue here concerning the correctness of the
amounts of the tax liabilities for 1996 and 1997.2 There is also
no dispute that the taxes were properly assessed and that
petitioner has failed to pay these liabilities. We, therefore,
review the Appeals Office’s refusal to lift the tax lien by the
standard whether it was an abuse of discretion; i.e., whether it
was arbitrary, capricious, or without sound basis in fact or law.
We do not substitute our judgment for that of the Appeals Office.
See sec. 6330(d); Murphy v. Commissioner, 125 T.C. 301, 308, 320-
2 The original assessment was corrected to reflect the amounts
shown on petitioner’s 1996 and 1997 returns that were filed on
Feb. 7, 2005.
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