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concluded that the check was returned for insufficient funds.
Moreover, there is no evidence that petitioner raised the
computational issue during the section 6330 hearing. We agree
with respondent that, for failure to raise the computational
issue during the section 6330 hearing, petitioner is precluded
from raising it with us. See Giamelli v. Commissioner, 129 T.C.
, (2007) (slip op. at 15) (“we do not have authority to
consider section 6330(c)(2) issues that were not raised before
the Appeals Office”); Magana v. Commissioner, 118 T.C. 488, 493
(2002) (“in our review for an abuse of discretion under section
6330(d)(1) * * * generally we consider only arguments, issues,
and other matter that were raised at the collection hearing”);
sec. 301.6330-1(f)(2), Q&A-F5, Proced. & Admin. Regs. (2002).
Petitioner has failed to prove that Appeals erred in making
the determination.
To reflect the foregoing,
Decision will be entered
for respondent.
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Last modified: March 27, 2008