Charles Michael Snyder - Page 6

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          statutory notice of deficiency with respect to the underlying tax           
          liability or did not otherwise have an opportunity to dispute               
          that liability.  Sec. 6330(c)(2)(B); Montgomery v. Commissioner,            
          122 T.C. 1, 8-9 (2004).                                                     
               This Court has jurisdiction under section 6330 to review the           
          Commissioner’s administrative determinations.  Sec. 6330(d);                
          Iannone v. Commissioner, 122 T.C. 287, 290 (2004).  We review               
          nonliability administrative determinations for abuse of                     
          discretion, and we review determinations as to the underlying tax           
          liability de novo.  Fishbach v. Commissioner, T.C. Memo. 2005-38            
          (citing Hoffman v. Commissioner, 119 T.C. 140, 144-145 (2002),              
          and Sego v. Commissioner, 114 T.C. 604, 610 (2000)).  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).  In reviewing for abuse of discretion, we generally                 
          consider only arguments, issues, and other matters that were                
          raised at the administrative hearing or otherwise brought to the            
          attention of the Office of Appeals.  Magana v. Commissioner, 118            
          T.C. 488, 493 (2002); sec. 301.6320-1(f)(2), Q&A-F5, Proced. &              
          Admin. Regs.                                                                









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