Claude E. and Dana L. Salazar - Page 16




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          appropriateness of collection actions, and collection                       
          alternatives.  Sec. 6330(c)(2)(A).  A taxpayer may contest the              
          existence or amount of the underlying tax liability if the                  
          taxpayer failed to receive a notice of deficiency for the tax               
          liability in question or did not otherwise have an earlier                  
          opportunity to dispute the tax liability.  Sec. 6330(c)(2)(B);              
          see also Sego v. Commissioner, 114 T.C. 604, 609 (2000).                    
               Following a hearing, the Appeals Office must make a                    
          determination whether the Secretary may proceed with the proposed           
          collection action.  We have jurisdiction to review the Appeals              
          officer’s determination.  Sec. 6330(d)(1).  Where the underlying            
          tax liability is properly at issue, we review that determination            
          de novo.  Goza v. Commissioner, 114 T.C. 176, 181-182 (2000).               
          Where the underlying tax liability is not at issue, we review the           
          determination for an abuse of discretion.  Id. at 182.                      
          II.  Offers-in-Compromise                                                   
               Petitioners first seek to compel respondent’s acceptance of            
          their offer-in-compromise.  Petitioners suggest that the failure            
          to accept their original offer-in-compromise was an abuse of                
          discretion.                                                                 
               We do not conduct an independent review of what would be an            
          acceptable offer-in-compromise.  Murphy v. Commissioner, 125 T.C.           
          301, 320 (2005), affd. 469 F.3d 27 (1st Cir. 2006); Fowler v.               
          Commissioner, T.C. Memo. 2004-163.  The extent of our review is             







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