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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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