- 5 - petitioners had a balance due on the contract for deed relating to their residence of $67,836, and petitioners’ residence had a fair market value of approximately $460,000. On June 19, 2006, petitioners timely filed a petition with this Court. In their petition, petitioners alleged only the following error: The Respondent erred in determining that a short-term extension of time to June 2007 for the petitioners to refinance or sell their home pursuant to a balloon payment on their Contract for Deed and thereby raise the funds to pay the liabilities was not an appropriate collection alternative * * *. Discussion Summary judgment is appropriate where the pleadings, answers to interrogatories, depositions, admissions, and other material show there is no genuine issue as to any material fact and that a decision may be rendered as a matter of law. Rule 121(b); Beery v. Commissioner, 122 T.C. 184, 187 (2004). Under section 6330(d)(1), where a taxpayer’s underlying tax liability is not at issue, we generally review respondent’s Appeals Office notice of determination for an abuse of discretion. Sego v. Commissioner, 114 T.C. 604, 609-610 (2000). In an Appeals Office hearing, generally respondent is required to consider issues raised by a taxpayer includingPage: Previous 1 2 3 4 5 6 7 8 9 NextLast modified: November 10, 2007