- 10 - In accordance with the foregoing, the Appeals Office must make a collection determination after reviewing the matters prescribed in section 6330(c)(1) and (2) and considering whether the proposed collection action balances the need for efficient collection of taxes with the legitimate concern of the taxpayer that the collection be no more intrusive than necessary. Sec. 6330(c)(3). After the Appeals Office makes a determination under section 6330(c), the taxpayer may petition the Tax Court for review. Sec. 6330(d). If the taxpayer’s underlying tax liability is properly at issue, we review any determination regarding the underlying tax liability de novo. Sego v. Commissioner, 114 T.C. 604, 610 (2000). We review any other administrative determinations regarding the proposed collection action for abuse of discretion. Id. Analysis As previously discussed, on May 22, 2002, the Court entered an agreed decision at docket No. 9419-01 that petitioner was liable for a deficiency of $34,163 for the taxable year 1998, as 4(...continued) respect to which subsection (d)(2)(B) applies. Sec. 6330(d)(2)(B) provides that the Office of Appeals retains jurisdiction with respect to any determination made under sec. 6330 if the taxpayer requests a subsequent hearing, after exhausting all administrative remedies, to raise an issue that a change in his or her circumstances affects the determination.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 NextLast modified: March 27, 2008