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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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