- 7 - (ii) the relevant issues raised by the taxpayer, (iii) challenges to the underlying tax liability by the taxpayer, where permitted, and (iv) whether any proposed collection action balances the need for the efficient collection of taxes with the legitimate concern of the taxpayer that the collection action be no more intrusive than necessary. Sec. 6330(c)(3). We have jurisdiction to review the Appeals officer´s determination where we have jurisdiction over the type of tax involved in the case. Sec. 6330(d)(1)(a). Generally, we may consider only those issues that the taxpayer raised during the section 6330 hearing or otherwise brought to the attention of the Appeals Office. Magana v. Commissioner, 118 T.C. 488, 493 (2002). We also have jurisdiction to consider the taxpayer’s tax liabilities for years that were not the subject of the notice of determination insofar as they are relevant to computing the taxpayer’s tax liability for years that are the subject of the notice of determination. Freije v. Commissioner, 125 T.C. 14, 27 (2005). Where the underlying tax liability is at issue, we review the determination de novo. Sego v. Commissioner, 114 T.C. 604, 610 (2000). Where the underlying tax liability is not at issue, we review the determination for abuse of discretion. Id. An abuse of discretion is defined as any action that is unreasonable, arbitrary or capricious, clearly unlawful, orPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007