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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). The Appeals officer must consider those
issues, verify that the requirements of applicable law and
administrative procedures have been met, and consider “whether
any proposed collection action balances the need for the
efficient collection of taxes with the legitimate concern of the
person [involved] that any collection action be no more intrusive
than necessary.” Sec. 6330(c)(3)(C).
After the Appeals hearing process, section 6330 gives this
Court jurisdiction to review the Appeals officer’s determination.
Where the underlying tax liability is properly at issue, we
review the Appeals determination with respect to the existence
and amount of tax liability de novo. Sego v. Commissioner, 114
T.C. 604, 610 (2000); Goza v. Commissioner, 114 T.C. 176, 181-182
(2000). When the underlying tax liability is not properly at
issue, we review the Appeals officer’s determination using an
abuse of discretion standard. Sego v. Commissioner, supra at
610; Goza v. Commissioner, supra at 181-182.
At the hearing, a taxpayer may challenge the existence and
amount of the underlying tax liability if he or she received no
notice of deficiency or did not otherwise have an opportunity to
dispute such tax liability. Sec. 6330(c)(2)(B). A self-reported
tax liability along with statutory penalties and interest
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Last modified: November 10, 2007