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so doing, the Appeals Office is required to take into
consideration: (1) Verification presented by the Secretary that
the requirements of applicable law and administrative procedures
have been met, (2) relevant issues raised by the taxpayer, and
(3) whether the proposed levy action appropriately balances the
need for efficient collection of taxes with a taxpayer’s concerns
regarding the intrusiveness of the proposed levy action. Sec.
6330(c)(3).
Section 6330(d)(1) grants this Court jurisdiction to review
the determination made by the Appeals Office in connection with
the section 6330 hearing. Where the underlying tax liability is
properly at issue, the Court reviews any determination regarding
the underlying tax liability de novo. Sego v. Commissioner,
supra at 610. The Court reviews any other administrative
determination regarding the proposed levy action for abuse of
discretion. Id. An abuse of discretion occurs if the Appeals
Office exercises its discretion “arbitrarily, capriciously, or
without sound basis in fact or law.” Woodral v. Commissioner,
112 T.C. 19, 23 (1999).
A. 1996, 1997, and 1998
1. Notice of Deficiency
Petitioner argues that he did not receive a valid notice of
deficiency for 1996, 1997, and 1998. However, petitioner does
not dispute that respondent mailed him a notice of deficiency
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