Jorge Torres - Page 8

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          appropriate spousal defenses, challenges to the appropriateness             
          of collection actions, and offers of collection alternatives.               
          Sec. 6330(c)(2)(A).  Section 6330(c)(2)(B) limits the taxpayer’s            
          ability to challenge the underlying tax liability during the                
          hearing.  Specifically, the taxpayer may “raise at the hearing              
          challenges to the existence or amount of the underlying tax                 
          liability for any tax period if the person did not receive any              
          statutory notice of deficiency for such tax liability or did not            
          otherwise have an opportunity to dispute such tax liability.”               
          Sec. 6330(c)(2)(B).                                                         
               The taxpayer may seek judicial review of a determination               
          made by the Appeals officer.  Sec. 6330(d).  This Court has                 
          jurisdiction to review the Commissioner’s administrative                    
          determination where the underlying tax liability is of a type               
          over which this Court normally has deficiency jurisdiction.  Id.;           
          Goza v. Commissioner, 114 T.C. 176, 181 (2000).  When the                   
          underlying tax liability is properly at issue, the Court will               
          review the administrative determination on a de novo basis.  Sego           
          v. Commissioner, 114 T.C. 604, 610 (2000) (quoting H. Conf. Rept.           
          105-599, at 266 (1998), 1998-3 C.B. 747, 1020).  When the                   
          validity of the underlying tax liability is not properly at                 
          issue, the Court will review the Appeals officer’s determination            
          for abuse of discretion.  Id.                                               







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