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involved in the case. Sec. 6330(d)(1)(A); see Iannone v.
Commissioner, 122 T.C. 287, 290 (2004). Generally, 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. at 182. 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).
2004 Supplemental Determination
In the petition, petitioner alleged certain infirmities in
the initial notice of determination, including respondent's
failure to: (i) Provide a hearing; (ii) verify satisfaction of
the requirements of applicable laws or administrative procedures;
(iii) state that the Appeals employee making the determination
had no prior involvement with the liabilities at issue; and (iv)
balance the needs of efficient collection against petitioner's
legitimate concerns that the collection action be no more
intrusive than necessary. We conclude that these issues are now
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