Brad Daniel Clarke, Sr. - Page 8




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          (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, or                 







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