- 10 - to challenge the underlying liability. Alternatively, the estate asserts that it is a separate person entitled to its own collection review proceeding. The estate’s arguments imply that we may consider arguments about the underlying tax liability never raised before in the administrative collection review proceedings. This Court’s jurisdiction in a collection review proceeding under sections 6320 and 6330 is dependent on the issuance of a valid notice of determination by respondent’s Appeals Office and the timely filing of a petition for review. Sec. 6330(d); see also Smith v. Commissioner, 124 T.C. 36, 38 (2005). The focus of any review in this Court under section 6330(d) is the determination of respondent’s Appeals Office under section 6330(c). Offiler v. Commissioner, 114 T.C. 492, 498 (2000). Under section 6330(c)(3), the determination of the Appeals officer shall take into consideration “the issues raised under paragraph (2)”.3 Section 6330(c)(2)(A) permits the taxpayer to 3 Sec. 6330(c)(2) provides as follows: (2) Issues at hearing.-- (A) In general.--The person may raise at the hearing any relevant issue relating to the unpaid tax or the proposed levy, including-- (i) appropriate spousal defenses; (ii) challenges to the appropriateness of (continued...)Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 NextLast modified: November 10, 2007