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to the extent such use would result in the
taxpayer not having adequate means to provide
for basic living expenses.
Regulations adopted pursuant to section 7122 set forth three
grounds for the compromise of a liability: (1) Doubt as to
liability; (2) doubt as to collectibility; or (3) promotion of
effective tax administration. Speltz v. Commissioner, supra at
172; sec. 301.7122-1, Proced. & Admin. Regs. In her petition,
petitioner asserts that there was an abuse of discretion as to
all three grounds, although she pursued only promotion of ETA at
the CDP hearing.
Generally, we may consider only those issues that the
taxpayer raised during a section 6330 hearing. Sapp v.
Commissioner, T.C. Memo. 2006-104; sec. 301.6330-1(f)(2), Q&A-F5,
Proced. & Admin. Regs.; see also Magana v. Commissioner, 118 T.C.
488, 493 (2002). Respondent asserts that petitioner did not
raise the issue of doubt as to liability at her Appeals hearing,
which petitioner disputes. In any event, petitioner has failed
to aver facts or legal argument sufficient to show error in
respondent’s assessment. See Poindexter v. Commissioner, 122
T.C. 280, 284-285 (2004), affd. 132 Fed. Appx. 919 (2d Cir.
2005). Petitioner has not argued that the computation of the AMT
on her year 2000 return is incorrect, but she argues instead that
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