Edward W. Clough - Page 7

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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.               
              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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