§8332

nable time.” Id. at 315. Similarly, in Giamelli v. Commissioner, 129 T.C. 107, 113 (2007), we found that “if an issue is never raised at [a hearing with the Appeals officer], it cannot be part of the Appeals officer’s determination.” - 13 - Action, sec. 8332, at 161-62 (2006). In section 6015(f) innocent-spouse cases, however, precedent constrains us to combine the independent factfinding of a trial de novo with an abuse-of-discretion standard of review. Another difference between our practice a