Nick A. Zotos (Satterlee Stephens Burke & Burke, New York) has published Service Collection Abuse of Discretion: What is the Appropriate Standard of Review and Scope of the Record in Collection Due Process Appeals?, 62 Tax Law. 223 (2008). Here is part of the Introduction:

In 1998, Congress significantly altered the landscape of Service collection practices by enacting legislation instituting additional due process safeguards that must be followed before the Service may seize property. Collectively referred to as collection due process (CDP), sections 6320 and 6330 of the Code grant taxpayers the right to notice and a hearing before the Service may seize property to satisfy a tax debt.

This Article begins with an overview of CDP procedures under sections 6320 and 6330. Second, it discusses the differing views of courts and commentators on the appropriate standard of review for CDP determinations and the proper scope of the appellate record. Third, it summarizes Tax Court decisions and summary opinions to identify trends as to what constitutes abuse of discretion. Finally, it explains why taxpayers are losing the vast majority of CDP appeals and evaluates the appropriateness of abuse of discretion review.